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United States Government Accountability Office:
GAO:
Report to Congressional Requesters:
February 2012:
U.S. Export-Import Bank:
Actions Needed to Promote Competitiveness and International
Cooperation:
GAO-12-294:
GAO Highlights:
Highlights of GAO-12-294, a report to congressional requesters.
Why GAO Did This Study:
The U.S. Export-Import Bank (Ex-Im), the United States’ official
export credit agency (ECA), helps U.S. firms export goods and services
by providing a range of financial products. Ex-Im, whose primary
mission is to support jobs through exports, has a range of policy
requirements, including support of small business. The Organisation
for Economic Cooperation and Development (OECD) Arrangement governs
aspects of U.S. and some foreign countries’ ECAs. GAO examined (1)
Ex-Im’s mission and organization compared with ECAs from other Group
of Seven (G-7) countries (major industrialized countries that consult
on economic issues), (2) Ex-Im’s policy requirements compared with
other G-7 ECAs, (3) Ex-Im’s domestic content policy compared with
other G-7 ECAs, and (4) the OECD Arrangement’s role in governing ECA
activities.
What GAO Found:
The United States and other G-7 countries have ECAs that support
domestic exports, but Ex-Im differs from other ECAs in several
important ways, including its explicit mission to promote domestic
employment. The G-7 ECAs range from government agencies to private
companies contracted by governments. Most of these ECAs, including Ex-
Im, are expected to supplement, not compete with, the private market.
Ex-Im offers direct loans, which were increasingly utilized during the
recent financial crisis, while European ECAs do not.
Ex-Im has specific mandates in areas where other G-7 ECAs have broad
directives. Ex-Im has specific mandates to support small business and
environmentally beneficial exports, while other ECAs are broadly
directed to support such exports. In addition, Ex-Im has other
mandates and legal requirements, such as shipping certain exports on
U.S.-flagged carriers and conducting economic impact assessments for
large transactions, which other G-7 ECAs do not.
Ex-Im’s requirements for the level of domestic content in the exports
it fully finances are higher and generally less flexible than those of
other G-7 ECAs. Ex-Im requires 85 percent domestic content for medium-
and long-term transactions to receive full financing, while other ECAs’
domestic content requirements generally range between zero and 51
percent. Ex-Im’s policy on supporting local costs can result in more
foreign content support in some transactions. While Ex-Im has modified
its method for calculating domestic content, its threshold for
receiving full financing for medium- and long-term transactions has
not changed since 1987, and the policy and its overall impact on jobs
has not been studied systematically. Other ECAs have modified their
policies in recent years, citing increasing global content of
industrial production. In its charter, Ex-Im is directed to provide
financing competitive with that of other ECAs, as well as to support
U.S. jobs.
The OECD Arrangement has expanded to regulate additional aspects of
officially supported export credits, but increasing activity of
nonmembers threatens its ability to provide a level playing field for
exporters. Several agreements have been made that decrease subsidies
and increase transparency among ECAs. However, these agreements apply
only to participant ECAs, and important emerging countries, including
China, are not part of the Arrangement. Officials from several G-7
ECAs and other institutions identified effective engagement with these
countries on export credit issues as being increasingly important and
presenting challenges for the OECD Arrangement and its participants.
What GAO Recommends:
GAO recommends (1) that Ex-Im conduct a systematic review to assess
how well its domestic content policy continues to support Ex-Im’s
mission, and (2) that the Department of the Treasury, with Ex-Im and
international counterparts, develop strategies for further engagement
on export credit issues with emerging economy countries. Ex-Im stated
it considers content policy in its annual competitiveness assessments,
but did not comment directly on the recommendation. Treasury stated it
supports encouraging emerging market economies’ participation
concerning export credit issues and is engaged in that activity, but
did not state whether it agreed with the recommendation.
View [hyperlink, http://www.gao.gov/products/GAO-12-294]. For more
information, contact Loren Yager at (202) 512-4347 or yagerl@gao.gov.
[End of section]
Contents:
Letter:
Background:
Ex-Im Differs from the Other G-7 ECAs in Several Important Ways,
Including Its Explicit Mission to Promote Domestic Employment:
Ex-Im Has Specific Mandates and Operates under More Policy
Requirements than Other ECAs:
Ex-Im's Domestic Content Requirements Are Generally Higher and Less
Flexible than Those of Other ECAs:
The OECD Arrangement Has Decreased Export Credit Subsidies, but the
Increasing Importance of Nonmembers Threatens Its Future Effectiveness:
Conclusions:
Recommendations for Executive Action:
Agency Comments and Our Evaluation:
Appendix I: Objectives, Scope, And Methodology:
Appendix II: Comments From The U.S. Export-Import Bank:
Appendix IIII: GAO Contact And Staff Acknowledgments:
Tables:
Table 1: Missions and Related Characteristics of the G-7 ECAs:
Table 2: Domestic Content Policies of the G-7 ECAs, Including Minimum
Domestic Content to Receive Full Medium-and Long-Term Support:
Figures:
Figure 1: Official Export Credit Agencies of the G-7 Countries:
Figure 2: New Business by G-7 Export Credit Agency, 2010:
Figure 3: Medium-and Long-Term Official Export Credits, 2006-2010:
Figure 4: Comparison of Selected Products Offered by G-7 ECAs:
Figure 5: Ex-Im Direct Lending, 1998-2011:
Figure 6: G-7 ECAs with External Directives to Support Small Business
Exporters and Environmentally Beneficial Exports:
Figure 7: G-7 ECAs with Select External Requirements:
Figure 8: Domestic Content Share of Manufacturing Exports among G-7
Countries, 2005:
Figure 9: Domestic Content of Select U.S. Exports, 1995 to 2005:
Figure 10: Average Domestic Content for Ex-Im's Medium-and Long-term
Transactions Containing Foreign Content, 1997 through 2010:
Figure 11: Estimated Medium-and Long-Term Official Export Credits,
2006-2010:
Figure 12: Estimated Activity Levels for Export-Import Banks of China,
India, and the United States, 2000 and 2010:
Abbreviations:
CEO: chief executive officer:
CIRR: Commercial Interest Reference Rate:
Coface: Compagnie Française d'Assurance pour le Commerce Extérieur:
CRS: Congressional Research Service:
ECA: export credit agency:
ECGD: Export Credits Guarantee Department:
EDC: Export Development Canada:
EU: European Union G-7Group of Seven:
GDP: gross domestic product:
JBIC: Japanese Bank for International Cooperation:
KfW: KfW Bankengruppe:
NEXI: Nippon Export and Investment Insurance:
OECD: Organisation for Economic Cooperation and Development:
OPIC: Overseas Private Investment Corporation:
SACE: Servizi Assicurativi del Commercio Estero:
SBA: Small Business Administration:
SIMEST: Societa Italiana per le Imprese all'Estero:
UK: United Kingdom:
[End of section]
United States Government Accountability Office:
Washington, DC 20548:
February 7, 2012:
The Honorable Gary Miller:
Chairman:
International Monetary Policy and Trade:
Subcommittee:
The Honorable Judy Biggert:
Chairman:
Insurance, Housing and Community Opportunity Subcommittee:
Committee on Financial Services:
House of Representatives:
The Honorable Gregory Meeks:
House of Representatives:
As the nation's official export credit agency (ECA), the U.S. Export-
Import Bank (Ex-Im) supports U.S. exporters by providing loans,
guarantees, and insurance, particularly during times of economic
crisis when private financing is not available. Ex-Im's primary
mission is to create U.S. jobs through exports. In addition, Ex-Im has
a variety of other policy requirements, including congressional
mandates to support small businesses and promote environmentally
beneficial exports, as well as policies regarding the amount of U.S.
content in the exports it finances. In its charter, Ex-Im is directed
to provide financing competitive with the rates, terms, and other
conditions available from other ECAs.
An international agreement, the Organisation for Economic Cooperation
and Development (OECD) Arrangement on Officially Supported Export
Credits (the Arrangement), governs various aspects of U.S. and other
member countries' ECAs.[Footnote 1] The Arrangement aims to promote a
level playing field where exporters compete on the basis of price and
quality rather than export credit support, including any subsidies.
The Group of Seven (G-7) major industrialized countries are all
participants in the Arrangement. However, some countries with
substantial export credit activity--including China, India, and
Brazil--are not participants in this agreement.
In the context of Ex-Im's latest reauthorization, Congress asked GAO
to examine how Ex-Im's export credit support and policy requirements
compare with those of other export credit agencies in developed
countries. This review examines (1) Ex-Im's mission, organization,
market orientation, and product offerings compared with those of the
other G-7 ECAs; (2) Ex-Im's policy requirements compared with those of
the other G-7 ECAs; (3) Ex-Im's domestic content policy compared with
those of the other G-7 ECAs; and (4) the role of the OECD Arrangement
in governing ECA activities.
To address these objectives, we reviewed relevant documentation
related to Ex-Im and the other G-7 ECAs, including legislation, annual
reports, OECD and academic reports, and Ex-Im's annual Competitiveness
Reports. We met with officials from the following ECAs: Export
Development Canada (EDC) in Canada, Coface in France, Export Credits
Guarantee Department (ECGD) in the United Kingdom, Servizi
Assicurativi del Commercio Estero (SACE) in Italy, and Hermes in
Germany. We also met with officials from oversight organizations in G-
7 countries, as well as the OECD and the Berne Union, an association
of export credit and investment insurance providers. We spoke via
telephone with officials from the Japanese ECAs, the Japanese Bank for
International Cooperation (JBIC) and Nippon Export and Investment
Insurance (NEXI). We interviewed Ex-Im officials from various
divisions of the organization. We also spoke with officials from other
U.S. government agencies, including the Departments of the Treasury
and State, as well as the Small Business Administration. We
interviewed a variety of experts on China's export credit activities,
including experts at American University and the Brookings
Institution. Appendix I provides more information on our scope and
methodology.
We conducted this performance audit from February 2011 to February
2012 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
Background:
Export credits are financing arrangements designed to mitigate risks
to buyers and sellers associated with international transactions.
[Footnote 2] Export credits generally take the form of direct loans,
loan guarantees, and export credit insurance, and may be short-term (0-
1 year), medium-term (1-7 years), and long-term (7 plus years).
[Footnote 3] (See textbox below.) Buyers and sellers in international
transactions face unique risks, such as foreign exchange risk,
difficulties in settling disputes when damages to shipments occur, or
instability in the buyer's country. For these reasons, lenders may be
reluctant to finance a buyer's purchase of foreign goods. Export
credit products are meant to facilitate international transactions by
mitigating these risks. Official ECAs are organizations that provide
export credits with explicit government backing, where either the
government, or the government-owned ECA, assumes the risk and is
financially liable for reimbursing the exporter or the lending
institution if the buyer fails to pay.
[Text box:
ECA Export Credit Products Defined:
* Export credit insurance: An insurance policy that protects the
exporter from the risk of nonpayment by foreign buyers for commercial
and political reasons;
* Loan guarantee: An ECA guarantees a lender's financing to an
international buyer of goods or services, promising to pay the lender
if the buyer defaults;
* Direct loan: The ECA makes a fixed-rate loan directly to an
international buyer of goods and services;
* Interest make-up: In lieu of making direct loans, an ECA pays a
lender the difference between the OECD minimum interest rate and
commercial interest rates.
End of text box]
Ex-Im, the official export credit agency of the United States, is an
independent government agency operating under the Export-Import Bank
Act of 1945, as amended. Ex-Im currently has about 400 employees. Its
mission is to support U.S. exports and jobs by providing export
financing on terms that are competitive with those of official export
credit support offered by other governments. Since fiscal year 2008,
Ex-Im has been "self-sustaining" for appropriations purposes,
financing its operations from receipts collected from its borrowers.
[Footnote 4] Ex-Im provides export credit insurance, direct loans, and
loan guarantees in support of U.S. exports. In fiscal year 2011, Ex-Im
authorized $32.7 billion: $7.0 billion in export credit insurance,
$6.3 billion in direct loans, and $19.4 billion in loan guarantees. Ex-
Im has a risk exposure limit of $100 billion, meaning that the total
outstanding value of all loans, guarantees, and insurance contracts
cannot exceed this number; at the end of fiscal year 2011, Ex-Im had a
total exposure of $89.2 billion.
The other G-7 countries, which include some of the largest exporters,
all have at least one ECA. See figure 1.
Figure 1: Official Export Credit Agencies of the G-7 Countries:
[Refer to PDF for image: illustrated world map]
Country: United States
Name of official export credit agency: U.S. Export-Import Bank
Referred to in report: Ex-Im.
Country: Canada
Name of official export credit agency: Export Development Canada;
Referred to in report: EDC.
Country: France[A];
Name of official export credit agency: Compagnie Frangaise d'Assurance
pour le Commerce Exterieur;
Referred to in report: Coface.
Country: Germany[A];
Name of official export credit agency: Consortium of Euler
Kreditversicherungs-AG and PricewaterhouseCoopers AG
Wirtschaftsrufunesellschaft;
Referred to in report: Hermes.
Country: Italy[A];
Name of official export credit agency: Servizi Assicurativi del
Commercio Estero;
Referred to in report: SACE.
Country: Japan;
Name of official export credit agency: Bank for International
Cooperation;
Referred to in report: JBIC;
Name of official export credit agency: Nippon Export and Investment
Insurance;
Referred to in report: NEXI.
Country: United Kingdom;
Export Credits Guarantee Department;
Referred to in report: ECGD.
Sources: GAO analysis of documents from OECD and Hermes.
[A] France, Italy, and Germany each have an additional government or
government-directed institution that offers products that could be
characterized as officially supported export credits. Societa Italiana
per le Imprese all'Estero (SIMEST) in Italy and Natixis in France have
interest make-up programs. KfW IPEX-Bank in Germany offers loans at
the OECD minimum interest rate in support of export-related
transactions.
[End of figure]
G-7 ECAs differ in the magnitude and types of their activities. All
offer medium-and long-term officially supported export credits.
According to Ex-Im, this financing is subject to the most intense
international competition, where the support of an ECA can influence
who wins overseas deals. Ex-Im's annual competitiveness reports
compare ECAs on the basis of their medium-and long-term export credit
support programs. ECAs also can provide other products and services in
addition to these medium-and long-term officially supported export
credits; some of the G-7 ECAs offer short-term export credits, market-
based export credits (called "market windows"), and other non-export
credit products such as investment insurance. This can complicate
comparisons among institutions, as some ECAs offer products that are
also offered by other types of institutions, such as development or
finance institutions, in other countries. ECAs do not typically
compete with one another in the area of short-term credits.
Figure 2 shows each ECA's total new business in 2010, providing a
comparison between medium-and long-term officially supported export
credits and other new business in that same year. Germany was the
largest provider of medium-and long-term export credits, followed by
France and the United States. Japan's two ECAs, combined, had the
largest amount of total new business in 2010, but only a very small
portion was for officially supported medium-and long-term export
credits; the remainder included other products such as overseas
investment loans, untied loans, and overseas untied loan
insurance.[Footnote 5] This was also true of Canada's ECA, EDC, which
had the second highest volume of total new business. A large
proportion of the new business was attributable to short-term credit
insurance.
Figure 2: New Business by G-7 Export Credit Agency, 2010:
[Refer to PDF for image: stacked vertical bar graph]
Country: U.S.;
New medium- and long-term export credits: $13 billion;
Other new business: $10.0 billion.
Country: Canada;
New medium- and long-term export credits: $2.5 billion;
Other new business: $79.9 billion.
Country: France;
New medium- and long-term export credits: $17.4 billion;
Other new business: $6.7 billion.
Country: Germany;
New medium- and long-term export credits: $22.5 billion;
Other new business: $20.6 billion.
Country: Italy;
New medium- and long-term export credits: $5.3 billion;
Other new business: $8.5 billion.
Country: Japan;
New medium- and long-term export credits: $2.9 billion;
Other new business: $115.2 billion.
Country: United Kingdom;
New medium- and long-term export credits: $1.9 billion;
Other new business: $2.6 billion.
Sources: Report to the U.S. Congress on Export Credit Competition and
the Export-Import Bank of the United States, period January 2010—
December 2010, and GAO analysis of ECA annual reports.
Notes: "Other new business" is calculated as the difference between
"total new business" and new medium-and long-term export credits.
"Total new business" is reported differently depending on the ECA. For
the United States, data are for total authorizations. For Canada, it
represents financial arrangements facilitated. For France, Germany,
Italy, and the United Kingdom, it means new guarantees. For Japan, it
is loan, guarantee, and investment commitments from JBIC, as well as
the total underwritten amount from NEXI.
The "total new business" number for Japan is for fiscal year 2010
(April 2010-March 2011), while the number for medium-and long-term
official export credits is an Ex-Im estimate for calendar year 2010.
For the United Kingdom, the "total new business" number is for fiscal
year 2010 (April 2010-March 2011), while the number for medium- and
long-term official export credits is for calendar year 2010.
[End of figure]
The G-7 ECAs have historically accounted for the majority of medium-
and long-term officially supported export credits, according to Ex-Im.
The share of national exports financed by official export credit
agencies is not large; on average, medium-and long-term ECA financing
as a share of total exports for each of the G-7 countries in 2008 was
0.6 percent. The United Kingdom's (UK) share was lowest at 0.1
percent, and Italy's was the highest at 1.2 percent; the remaining G-7
countries ranged between those value[Footnote 6]s. However, ECAs do
play a large role in certain sectors, such as aircraft. According to
Ex-Im, at its peak in 2009, ECA financing represented about 40 percent
of the total worldwide market for aircraft financing. In addition, the
recent financial crisis has increased the amount of ECA support for
exports; most G-7 ECAs saw notable increases in the volume of their
medium-and long-term officially supported export credits starting in
2008 or 2009 because private sector lenders and insurers were either
unwilling or unable to support transactions on their own. See figure 3
for estimates of the volume of medium-and long-term officially
supported export credits provided by each G-7 country over the past 5
years.[Footnote 7]
Figure 3: Medium-and Long-Term Official Export Credits, 2006-2010:
[Refer to PDF for image: horizontal bar graph]
Country: U.S.;
2006: 8.6;
2007: 8.2;
2008: 11;
2009: 17;
2010: 13
Country: Canada;
2006: 0.2;
2007: 0.5;
2008: 1.5;
2009: 2;
2010: 2.5.
Country: France;
2006: 7.3;
2007: 10.1;
2008: 8.6;
2009: 17.8;
2010: 17.4.
Country: Germany;
2006: 13.3;
2007: 8.9;
2008: 10.8;
2009: 12.9;
2010: 22.5.
Country: Italy;
2006: 4;
2007: 3.5;
2008: 7.6;
2009: 8.2;
2010: 5.3.
Country: Japan;
2006: 2.4;
2007: 1.8;
2008: 1.5;
2009: 2.7;
2010: 2.9.
Country: U.K.;
2006: 0.6;
2007: 0.4;
2008: 0.8;
2009: 1.4;
2010: 1.9.
Source: Report to the U.S. Congress on Export Credit Competition and
the Export-Import Bank of the United States, period January 2010—
December 2010.
Note: Data represent the medium-and long-term officially supported
export credits issued each year by country. U.S. data are presented on
a calendar-year basis. Data for Canada exclude market window and
domestic financing. For France, figures have been adjusted to exclude
defense. Data for Italy exclude untied or domestic activity. Figures
for Japan reflect an aggregation of JBIC export loans and an estimate
of NEXI medium-and long-term official export cover; the 2010 figure
for Japan is an Ex-Im estimate (data were not available).
[End of figure]
The OECD Arrangement on Officially Supported Export Credits is a set
of nonbinding rules among some OECD countries concluded in 1978 amid
increases in ECAs' provision of officially supported export credits.
The purpose of the Arrangement is to provide a framework for the use
of officially supported export credits; to promote a level playing
field, where competition is based on the price and quality of the
exported goods and not the financial terms provided; and to provide
transparency over programs and transactions. Participants to the
Arrangement are Australia, Canada, the European Union (EU),[Footnote
8] Japan, South Korea, New Zealand, Norway, Switzerland, and the
United States. Other countries may join following invitation and OECD
membership is not required. In addition, countries may belong to one
or more of the Arrangement's sector agreements--for example, Brazil is
a member of the Aircraft Sector Understanding--without being a full-
fledged participant.
The Arrangement applies to officially supported export credits with
repayment terms of 2 years or more. It places limitations on the terms
and conditions, such as interest rates, length of repayment terms, and
risk fees, of export credits that benefit from official support, and
it also contains a variety of reporting requirements to ensure
transparency. Another requirement is a down payment of 15 percent of
an export contract's value.[Footnote 9] The Arrangement and its
various sector agreements are negotiated among participants and
updated on an as-needed basis.[Footnote 10]
In addition to the OECD Arrangement, another export credit committee
at the OECD, the Working Party on Export Credits and Credit Guarantees
(Export Credit Group), was set up in 1963. Its general objectives are
to evaluate export credit policies, identify and resolve problems by
multilateral discussion, work out common guiding principles, and
improve cooperation between countries. To date, the Export Credit
Group has been the venue for important export credit agreements on
antibribery, environmental screening, and sustainable lending. All
OECD countries except Chile and Iceland are members.
The U.S. Department of the Treasury's Office of Trade Finance has lead
responsibility within the U.S. government for the development,
implementation, and enforcement of international trade and aid finance
policy, and its primary goal is to create and maintain a market-based,
competitive environment in which governments' financing of national
exports contains minimal subsidies. The Office of Trade Finance leads
the U.S. delegation to the OECD Arrangement. Other members of the
delegation include Ex-Im, the Departments of Commerce and State, the
Office of the U.S. Trade Representative, the U.S. Agency for
International Development, the U.S. Trade and Development Agency, and
other agencies whose programs or roles might be affected by the
negotiations.
EX-IM Differs From The Other G-7 ECAS In Several Important Ways,
Including Its Explicit Mission To Promote Domestic Employment:
Ex-Im is different from other G-7 ECAs in several significant ways,
including its mission, which is explicitly focused on creating
domestic jobs through exports. It is similar in its role as a
lender/insurer of last resort to four other ECAs, while Canada and
Italy have commercial market orientations and are not restricted from
competing with the private market. As an independent government
agency, Ex-Im's governance and organization type differ from those of
other ECAs, which range from government departments to private
companies contracted by governments. Ex-Im and other G-7 ECAs offer a
different mix of export credit and other financing products, which
provides them with different tools to help exporters. Ex-Im has an
advantage over some of the other ECAs because it offers direct loans,
which were useful during the financial crisis.
ECAs Differ in Their Missions and Organization Types:
Ex-Im's mission strongly emphasizes supporting domestic jobs through
exports, which is unique among the G-7 ECAs (see table 1). This aim
underlies certain Ex-Im policies, such as its economic impact analysis
requirement and its domestic content policy. Other ECA missions range
from promoting and supporting domestic exports to securing natural
resources.
Along with its mission is the ECA's "market orientation"--whether an
export credit agency supplements or competes with private markets for
export credit support. Most G-7 ECAs are directed to supplement the
private market; that is, they play a role as a "lender or insurer of
last resort," providing financing, guarantees, or insurance for
transactions that are too risky or are undesirable for commercial
support. In addition, according to G-7 ECA officials, European ECAs
must abide by EU law prohibiting them from supporting short-term
export credits to other EU member states and most OECD countries--
transactions that the private market is willing to support. Ex-Im's
role as a lender of last resort is emphasized in its charter. It must
report the purpose for each transaction it supports, either to provide
financing where private sector financing is unavailable or to meet
foreign competition. Canada's ECA, in contrast, has a commercial
market orientation and is not restricted from competing with the
private sector. Italy's ECA, while having to abide by EU law, also has
a commercial market orientation, according to Italian officials.
G-7 export credit agencies range from government agencies to private
companies contracted by governments, with different organization
types, governing structures, and processes for approving transactions
(see table 1). The ECAs that are managed by private companies, such as
those in France and Germany, experience more direct political
oversight, as their governments take a more direct role in approving
transactions and can take policy considerations into account on an
individual transaction basis.
Table 1: Missions and Related Characteristics of the G-7 ECAs:
Country: ECA: United States: Ex-Im;
Stated mission: Supports U.S. domestic jobs through exports by
providing export financing that is competitive with support offered by
other governments;
General market orientation: Lender/insurer of last resort;
ECA organization type: Independent government agency;
ECA governance and decision-making authority: Ex-Im has a board of
directors appointed by the President and confirmed by the Senate. The
board approves transactions above $10 million.[A]
Country: ECA: Canada: EDC;
Stated mission: Supports and develops Canada's domestic and export
trade and Canadian capacity to respond to domestic and international
business opportunities[B];
General market orientation: Commercial market orientation;
ECA organization type: Company wholly owned by the government
(Canadian Crown Corporation);
ECA governance and decision-making authority: A board of directors,
appointed by the Minister for International Trade and composed of
representatives primarily from the private sector, governs EDC and
approves transactions.[C]
Country: ECA: France: Coface;
Stated mission: Promotes and supports French exports and foreign
investments in the medium and long terms;
General market orientation: Insurer of last resort;
ECA organization type: Private company contracted by the government;
ECA governance and decision-making authority: In addition to its
private sector activities, Coface manages a separate account for state
export credits and reports to the Ministry of Finance, which takes
decisions on the largest and most important transactions.
Country: ECA: Germany: Hermes;
Stated mission: Promotes German exports; insures against the risk of
nonpayment for commercial and political reasons; opens new markets,
especially in emerging countries; and supports foreign countries,
particularly those in difficult phases of development and
restructuring;
General market orientation: Insurer of last resort;
ECA organization type: Consortium of two private companies contracted
by the government;
ECA governance and decision-making authority: The consortium manages
export credits on behalf of the government, but an Interministerial
Committee made up of the Ministries of Economics and Technology,
Finance, Economic Cooperation and Development, and the Federal Foreign
Office, make the approval decisions on transactions over 5 million
euros.
Country: ECA: Italy: SACE;
Stated mission: Supports Italian exporters and the
internationalization of Italian companies and banks;
General market orientation: Commercial market orientation;
ECA organization type: Joint stock company with shares owned by the
Ministry of Economy and Finance;
ECA governance and decision-making authority: A board of directors is
appointed by the Ministry of Economy and Finance in agreement with the
Ministry for Economic Development. Decisions on SACE's activity are
made by the Board of Directors, which also provides the Chairman and
the Chief Executive Officer (CEO) with specific powers of attorney.
Country: ECA: Japan: JBIC and NEXI;
Stated mission: JBIC: Secures natural resources, ensures
competitiveness of Japanese companies, responds to disruptions in the
international economy, and improves the environment.
NEXI: Contributes to Japan's economy by anticipating changes in the
market, responding to customer needs, and conducting insurance
business in covering risks that arise in international transactions
but are not covered by regular commercial insurance;
General market orientation: JBIC: lender of last resort/NEXI:
somewhere between an insurer of last resort and commercial market
orientation[D];
ECA organization type: Companies whose shares are owned by the
Ministry of Finance (JBIC) and the Ministry of Economy, Trade and
Industry (NEXI);
ECA governance and decision-making authority: JBIC: JBIC's parent
institution, Japan Finance Corporation, has a governor who approves
transactions over a certain threshold. JBIC's CEO or other executives
approve all other transactions;
NEXI: The Ministry of Economy, Trade and Industry approves
transactions over a certain threshold. NEXI's Chairman or a Director
approves all other transactions. The Board of Directors is an advisory
body rather than a decision-making body.
Country: ECA: United Kingdom: ECGD;
Stated mission: Complements the private market by providing assistance
to exporters and investors, principally in the form of insurance and
guarantees to banks;
General market orientation: Insurer of last resort;
ECA organization type: Department of the government;
ECA governance and decision-making authority: An Executive Committee
composed of ECGD Directors advises the Chief Executive on the
management of ECGD's business. A subcommittee--Risk Committee--
approves transactions.
Source: GAO analysis of ECA documents and interviews with ECA
officials.
[A] According to Ex-Im, the threshold for board approval for medium-
and long-term transactions is generally $10 million. However, there
are exceptions to this general rule. For example, all nuclear-related
transactions, irrespective of transaction value, must go to the board
for approval after an intra-agency clearance and congressional review
process. For other products, such as short-term insurance and working
capital guarantees, the approval threshold varies depending on the
specific product.
[B] EDC's mandate was temporarily expanded to include a domestic
component in 2009.
[C] The Chairperson of the board is appointed by the Governor in
Council.
[D] NEXI officials said that while NEXI has a complementary
relationship with the private sector, NEXI does not have a clear role
as an insurer of last resort. Rather, NEXI sees itself as somewhere
between an insurer of last resort and competing with the private
market.
[End of table]
Ex-Im and Other G-7 ECAs Offer Different Combinations of Export Credit
Support Products:
G-7 ECAs each offer a different mix of export credit and other
financial products. In general, a greater mix of products allows an
ECA more flexibility in responding to its customers' needs,
particularly during an economic crisis. Most ECAs offer standard
export credit products such as export credit insurance and loan
guarantees. However, ECAs may offer additional export credit products,
such as direct loans (United States, Japan, and Canada) and interest
make-up programs, where the ECA pays the difference between commercial
lending rates and fixed OECD minimum rates (Italy, France). ECAs also
may offer products that are not technically "export-related," but
that, according to Ex-Im, could possibly be used in lieu of or in
addition to standard export credits, such as investment insurance and
untied lending. Figure 4 shows a comparison of selected export credit
and other financial products offered by G-7 ECAs.
Figure 4: Comparison of Selected Products Offered by G-7 ECAs:
[Refer to PDF for image: illustrated table]
United States: Ex-Im;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Check];
Interest make-up: [Empty];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Check];
Loan guarantees: [Check];
Other selected financial products:
Working capital guarantees: [Check];
Foreign investment insurance: [Empty];
United loans: [Empty].
Canada: EDC;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Check];
Interest make-up: [Empty];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Empty];
Loan guarantees: [Check];
Other selected financial products:
Working capital guarantees: [Check];
Foreign investment insurance: [Check];
United loans: [Empty].
France: Coface;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Empty];
Interest make-up: [Check][A];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Check];
Loan guarantees: [Check][B];
Other selected financial products: [Empty];
Working capital guarantees: [Check];
Foreign investment insurance: [Check];
United loans: [Check].
Germany: Hermes;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Empty];
Interest make-up: [Check][C];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Check];
Loan guarantees: [Check][B[;
Other selected financial products: [Empty];
Working capital guarantees: [Empty];
Foreign investment insurance: [Check][A];
United loans: [Check][A].
Italy: Sace;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Empty];
Interest make-up: [Check][A];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Check];
Loan guarantees: [Check];
Other selected financial products:
Working capital guarantees: [Check];
Foreign investment insurance: [Check];
United loans: [Check].
Japan: JBIC and NEXI;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Check];
Interest make-up: [Empty];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Check];
Loan guarantees: [Check];
Other selected financial products:
Working capital guarantees: [Empty];
Foreign investment insurance: [Check];
United loans: [Check].
United Kingdom: ECGD;
Medium- and long-term official export credits, Official financing
support:
Direct loans: [Empty];
Interest make-up: [Empty];
Medium- and long-term official export credits, Official cover
(insurance and guarantees):
Export credit insurance: [Check];
Loan guarantees: [Check];
Other selected financial products:
Working capital guarantees: [Check];
Foreign investment insurance: [Check];
United loans: [Empty].
Sources: GAO analysis of ECA annual reports and discussions with ECA
officials.
[A] Provided by other institutions working in concert with these ECAs.
[B] France and Germany only offer loan guarantees for exports of
Airbus aircraft.
[C] Germany only offers interest make-up with regard to ECA-covered
ships that have been ordered from a German shipyard.
[End of figure]
Ex-Im's provision of direct loans proved to be useful during the
financial crisis, when commercial financing was expensive or
unavailable. While its direct lending program was little used in the
early 2000s, Ex-Im experienced a surge in demand for direct loans over
recent years, from $350 million in fiscal year 2008 (3 percent of its
total authorizations) to $6.3 billion in fiscal year 2011 (19 percent
of its total authorizations). See figure 5.
Figure 5: Ex-Im Direct Lending, 1998-2011:
[Refer to PDF for image: line graph]
Year: 1998;
Percentage of total authorizations: 0.973%.
Year: 1999;
Percentage of total authorizations: 6.908%.
Year: 2000;
Percentage of total authorizations: 7.38%.
Year: 2001;
Percentage of total authorizations: 9.427%.
Year: 2002;
Percentage of total authorizations: 2.921%.
Year: 2003;
Percentage of total authorizations: 0.555%.
Year: 2004;
Percentage of total authorizations: 1.705%.
Year: 2005;
Percentage of total authorizations: 0.
Year: 2006;
Percentage of total authorizations: 0.465%.
Year: 2007;
Percentage of total authorizations: 0.
Year: 2008;
Percentage of total authorizations: 2.472%.
Year: 2009;
Percentage of total authorizations: 14.43%.
Year: 2010;
Percentage of total authorizations: 17.413%.
Year: 2011;
Percentage of total authorizations: 19.32%.
Source: GAO analysis of Ex-Im data.
Note: The percentage of total authorizations is calculated in terms of
the dollar value of authorizations.
[End of figure]
The Japanese and Canadian direct loan programs also experienced
increases.[Footnote 11] The G-7 European ECAs, which do not have
direct loan programs, sought alternative solutions to mitigate the
lack of such financing.[Footnote 12] Several U.S. officials and a G-7
official stated that Ex-Im's direct loan program gave it an advantage
in responding to the needs of exporters and their customers during the
crisis.
EX-IM Has Specific Mandates And Operates Under More Policy
Requirements Than Other ECAS:
Ex-Im receives specific mandates from Congress and generally operates
under more policy requirements than other G-7 ECAs. Ex-Im's mandates
include specific targets from Congress for small business and
environmentally beneficial exports. Other G-7 ECAs may have broad
directives from their governments or ministries to focus on these
areas. Ex-Im also faces additional mandates and legal requirements
that other ECAs generally do not. For example, Ex-Im is statutorily
required to perform an economic impact analysis to assess whether a
project will negatively affect U.S. industries.
Ex-Im Has Specific Mandates on Small Business and Environmentally
Beneficial Exports where Other G-7 ECAs Have Broad Directives:
Ex-Im receives mandates from Congress that include specific targets in
the areas of small business and environmentally beneficial exports,
whereas some other G-7 ECAs have been given broad directives to focus
on these areas by their governments or ministries. Specifically, four
G-7 ECAs have received external directives to encourage small business
exporters, and two ECAs have received external directives to support
environmentally beneficial exports (figure 6). According to OECD
officials, Ex-Im is unique in that Congress gives it explicit policy
goals to pursue in addition to its general mandate to support domestic
exports. By contrast, other ECAs generally receive limited specific
policy guidance from their respective legislatures and oversight
ministries.
Figure 6: G-7 ECAs with External Directives to Support Small Business
Exporters and Environmentally Beneficial Exports:
[Refer to PDF for image: illustrated table]
Country: United States;
Small business: [Check];
Environmentally beneficial: [Check].
Country: Canada;
Small business: [Empty];
Environmentally beneficial: [Empty].
Country: France;
Small business: [Check];
Environmentally beneficial: [Empty].
Country: Germany;
Small business: [Empty];
Environmentally beneficial: [Empty].
Country: Italy;
Small business: [Empty];
Environmentally beneficial: [Check].
Country: Japan;
Small business: [Check];
Environmentally beneficial: [Empty].
Country: United Kingdom;
Small business: [Check];
Environmentally beneficial: [Empty].
Sources: GAO analysis of ECA documents and interviews with ECA and
government officials.
[End of figure]
Since the 1980s, Congress has required that Ex-Im make available a
certain percentage of its export financing for small business.
[Footnote 13] In 2002, Congress established several new requirements
for Ex-Im relating to small business, including increasing the small
business financing requirement from 10 to 20 percent. Related
congressional directives have included requirements to create a small
business division and to define standards to measure the bank's
success in financing small businesses.
From fiscal years 2006 to 2010, Ex-Im met the 20 percent small
business financing target, but did not in 2011. Ex-Im's small business
financing percent ranged from about 27 percent in fiscal year 2007 to
18.4 percent in fiscal year 2011.[Footnote 14] Because of the sharp
increase in overall Ex-Im financing in 2009 and 2010, meeting the 20
percent target has meant large annual increases in small business
financing. For example, Ex-Im small business financing increased by
about 58 percent between 2008 and 2010.[Footnote 15] According to Ex-
Im officials, the bank allocates significant resources to meeting its
small business mandate. About 27 staff work exclusively on small
business marketing, primarily in regional offices, according to Ex-Im
officials.[Footnote 16]
In 2010, Ex-Im developed and improved products to increase financing
options for small business, and to simplify application processes and
shorten turnaround time. For example, Ex-Im designed an express
insurance product to streamline the application process for short-term
export credit insurance. Other new products include ones aimed at
providing competitively priced working capital finance to U.S.
suppliers of U.S. exporters, and reinsurance to increase the capacity
of insurance companies to offer insurance to small business exporters
that have had difficulty obtaining short-term export credit since the
financial crisis.
Congress also mandates Ex-Im to support environmentally beneficial
exports and provides specific targets for such exports. However,
specific targets in this area have greatly exceeded Ex-Im financing.
In fiscal year 2008, Congress directed Ex-Im to allocate 10 percent of
its annual financing to renewable energy and environmentally
beneficial products and services. For fiscal years 2009 and 2010,
Congress directed Ex-Im to allocate 10 percent to a subset of those
exports--renewable energy and energy efficient end-use technologies.
We previously reported that Ex-Im had not come close to meeting this
10 percent target when it is applied to all of its environmentally
beneficial financing.[Footnote 17] Ex-Im has reported significant
increases in its renewable energy financing, from $101 million in 2009
to $332 million in 2010. In 2011, Ex-Im authorized about $889 million
in environmentally beneficial exports, of which about $721 million was
for renewable energy.
In contrast to Ex-Im's mandates, some ECAs are broadly directed by
their governments or ministries to support small business exports and
environmentally beneficial exports with, generally, no specific
targets to meet, according to G-7 officials. Specifically:
* The British government asks the Export Credits Guarantee Department
to promote small and medium-sized exporters, but the guidance ECGD
receives is suggestive, rather than a specific directive, according to
officials at the ECA.
* The French Ministry of Finance provided a target for its export
credit agency, Coface, to support 10,000 small and medium-sized
exporters by 2012, according to Coface officials. However, officials
stated that this target only applies to one product--market survey
insurance--and there are many other products that Coface uses to
promote exports of small businesses that are not associated with
specific external targets.
* Japan's Parliament also asks JBIC to support small and medium-sized
businesses, but provided a general directive to support such exporters
and did not include specific targets, according to JBIC officials.
* Italy's ECA, SACE, is directed by an interministerial decree to
designate renewable energy exports as a strategic sector, but no
specific targets are provided, according to SACE officials.
Some ECAs that do not have external directives from their governments
to support small businesses and environmentally beneficial exports
have developed internal initiatives to support such exports. For
example, in January 2011, Germany's ECA introduced a new product that
provides a fast-tracked application process allowing exporters to
receive export credit coverage for transactions of up to 5 million
euros in 4 days. Additionally, Canada's ECA has developed internal
initiatives to support environmentally beneficial exports. For
example, a team within Export Development Canada has been tasked by
EDC executives to come up with a clean technology strategy, and the
team is in the early stages of putting a strategy in place, according
to EDC officials.
Ex-Im Has Additional Mandates and Legal Requirements that Other ECAs
Generally Do Not Have:
Ex-Im has additional mandates and legal requirements that other ECAs
generally do not. These include (1) promotion of exports to sub-
Saharan Africa, (2) requirements to ship certain exports on U.S. flag
carriers, (3) carbon policy, (4) economic impact analysis, and (5)
congressional notification.[Footnote 18] All of these requirements,
except for the carbon policy, are the result of congressional
mandates. Although most ECAs do not have similar requirements (see
figure 7), as noted above, ECAs have different organizational and
governance structures. These differences can affect how a government
exercises policy considerations through its ECA. For example, Germany
has an interministerial board that approves individual transactions
and takes into account policy considerations on a case-by-case basis;
in contrast, Ex-Im is an independent agency and Congress exercises
policy considerations through programmatic mandates, according to a
Treasury official.
Figure 7: G-7 ECAs with Select External Requirements:
[Refer to PDF for image: illustrated table]
Country: United States;
Promotion of exports to specific regions of the world: [Check];
Shipping requirement: [Check];
Carbon policy: [Check];
Economic impact analysis: [Check];
Congressional notification: [Check].
Country: Canada;
Promotion of exports to specific regions of the world: [Empty];
Shipping requirement: [Empty];
Carbon policy: [Empty];
Economic impact analysis: [Empty];
Congressional notification: [Empty].
Country: France;
Promotion of exports to specific regions of the world: [Empty];
Shipping requirement: [Empty];
Carbon policy: [Empty];
Economic impact analysis: [Empty];
Congressional notification: [Empty].
Country: Germany;
Promotion of exports to specific regions of the world: [Empty];
Shipping requirement: [Empty];
Carbon policy: [Empty];
Economic impact analysis: [Empty];
Congressional notification: [Check].
Country: Italy;
Promotion of exports to specific regions of the world: [Empty];
Shipping requirement: [Empty];
Carbon policy: [Empty];
Economic impact analysis: [Empty];
Congressional notification: [Empty].
Country: Japan;
Promotion of exports to specific regions of the world: [Empty];
Shipping requirement: [Empty];
Carbon policy: [Empty];
Economic impact analysis: [Empty];
Congressional notification: [Empty].
Country: United Kingdom;
Promotion of exports to specific regions of the world: [Empty];
Shipping requirement: [Empty];
Carbon policy: [Empty];
Economic impact analysis: [Empty];
Congressional notification: [Empty].
Sources: GAO analysis of ECA documents and interviews with ECA and
government officials.
Note: France's ECA, Coface, stated that while it does not have a
specific shipping requirement, it treats shipping costs associated
with shipment on non-EU vessels as foreign content.
[End of figure]
Specifically, Ex-Im must consider the following mandates and legal
requirements when financing transactions:
* Promoting exports to sub-Saharan Africa. Congress mandates that Ex-
Im promote the expansion of its financial commitments in sub-Saharan
Africa under Ex-Im's loan, guarantee, and insurance programs. No other
G-7 ECAs have specific external requirements to support exports to sub-
Saharan Africa. In 2010, Ex-Im financed 132 transactions totaling $812
million in 20 sub-Saharan African countries. Ex-Im dedicates two full-
time employees to promoting exports to sub-Saharan Africa; others work
part-time on the issue.
* Requirement to ship certain exports on U.S.-flagged carriers.
Congress mandates that certain oceanborne cargo supported by U.S.
government credit entities must be transported on U.S. flag vessels
unless the requirement is waived by the U.S. Maritime Administration.
Ex-Im interprets this legislation to mean that exports financed
through its direct loan and long-term guarantee programs are subject
to the U.S. flag vessel requirement.[Footnote 19] In calendar year
2010, Ex-Im authorized 14 transactions valued at $2.9 billion that
were subject to this requirement.
* Carbon policy. Ex-Im is the only G-7 ECA legally required to adopt
an official carbon policy.[Footnote 20] Other ECAs have adopted
certain common environmental guidelines through the OECD. However,
specific conditions on carbon emissions are unique to Ex-Im. Ex-Im's
carbon policy, implemented in 2010, was developed in response to a
lawsuit challenging Ex-Im's compliance with provisions of the National
Environmental Policy Act. The carbon policy (1) promotes renewable
energy exports where carbon dioxide emission levels are very low to
zero, (2) establishes a $250 million facility to promote renewable
energy, and (3) calls for increased transparency in the tracking and
reporting of carbon dioxide emissions. In 2010, Ex-Im authorized 1
transaction valued at $887 million that was subject to the enhanced
due diligence review.[Footnote 21]
* Economic impact analysis. Congress requires Ex-Im to perform an
economic impact analysis to assess whether a project will negatively
affect U.S. industries either by reducing demand for goods produced in
the United States or by increasing imports to the United States. Other
G-7 ECAs do not have similar requirements, according to G-7 ECA
officials. As we have previously reported, Ex-Im uses a screening
process to identify projects with the most potential to have an
adverse economic impact, and then subjects the identified projects to
a detailed analysis. Of medium-and long-term transactions Ex-Im
authorized in 2010, 82 transactions, valued at $2.8 billion, were
subject to Ex-Im's economic impact analysis, with a small percentage
of those subject to detailed analysis.[Footnote 22]
* Congressional notification. Congress requires Ex-Im to submit a
detailed statement describing and explaining a transaction to Congress
prior to the Board of Directors' final approval if the transaction is
(1) in an amount equal to or greater than $100,000,000 or (2) related
to nuclear power or heavy water production facilities.[Footnote 23]
According to Hermes officials, Germany also sends a notification to
the German parliament's Committee on Budgets for transactions
exceeding 1 billion euros. According to Ex-Im, 38 transactions valued
at about $16 billion in 2010 were sent to Congress before the Board of
Directors' final approval of the transactions.
EX-IM'S Domestic Content Requirements Are Generally Higher And Less
Flexible Than Those Of Other ECAS:
Ex-Im's domestic content requirements are generally higher and less
flexible than those of other ECAs. To fully finance a medium-or long-
term transaction, Ex-Im requires that 85 percent of the value of the
transaction be supplied domestically. Other G-7 ECAs generally require
between zero to 51 percent domestic content. Additionally, key
elements of Ex-Im's domestic content policy have remained relatively
unchanged over two decades; at the same time, manufacturing patterns
have evolved toward greater integration in production and data show
that the domestic content of exports has decreased. Several ECAs have
modified their policies in recent years, often citing the increasingly
global content of industrial production as a primary reason for the
change.
Ex-Im's Current Policy Limits the Amount of Foreign Content in the
Exports It Finances:
Ex-Im's domestic content policy places limits on the amount of foreign
goods and services making up the exports it finances. Domestic content
refers to the portion of an exported good or service that is sourced
domestically. Ex-Im's policy is not the result of a statutory
requirement; according to Ex-Im, the policy reflects an attempt to
balance the interests of multiple stakeholders and Ex-Im's mission to
support U.S. jobs through export financing. Ex-Im's domestic content
policy for medium-and long-term transactions limits its level of
support to the lesser of (1) 85 percent of the total value of all
eligible goods and services in the U.S. export transaction,[Footnote
24] or (2) 100 percent of the U.S. content in all eligible goods and
services in the U.S. export transaction.[Footnote 25] In effect, Ex-Im
requires 85 percent domestic content to receive full financing for
medium-and long-term transactions but does not require a minimum
amount of domestic content to receive a portion of financing. See the
sidebar for two examples of how the domestic content policy affects
the level of support Ex-Im can provide.
[Side bar:
Examples Illustrating Ex-Im's Medium-and Long-Term Domestic Content
Policy:
Ex-Im's domestic content policy determines the total level of support
it can provide for medium- and long-term transactions by providing the
lesser of:
(1) 85 percent of the value of all eligible goods and services in the
contract. For example, A U.S. exporter is selling manufacturing
equipment to Mexico in a contract worth $10 million. Of the $10
million contract, $9 million is U.S. content and the remaining $1
million is foreign content. Thus, $9/$10 x 100 = 90 percent, which is
equal to or greater than 85 percent.
Therefore, the contract is eligible for 85 percent financing.
(2) 100 percent of the U.S. content of all eligible goods and services
in the contract. For example, A U.S. exporter is selling manufacturing
equipment to Mexico in a contract worth $10 million. Of the $10
million contract, $7.5 million is U.S. content and the remaining $2.5
million is foreign content. Thus, $7.5/$10 x 100 = 75 percent, which
is less than 85 percent.
Therefore, only the U.S. content is eligible for financing, so the
exporter would receive 75 percent financing. End of side bar]
Ex-Im has separate domestic content requirements for short-term
transactions--the percentage required to receive maximum coverage is
lower than for medium-and long-term transactions and the calculation
method differs. The short-term policy is generally more lenient for
small businesses than for other exporters. For example, small
businesses can satisfy the short-term domestic content requirement
based on aggregating all of the products in an export contract, while
non-small businesses must meet the minimum domestic content threshold
on a product-by-product basis. In addition, small businesses include
indirect costs in the calculation of domestic content.[Footnote 26]
According to Ex-Im, the difference reflects Ex-Im's directive to
consider the unique business requirements of small businesses.
Other ECAs Generally Have Lower and More Flexible Domestic Content
Requirements than Ex-Im:
Other G-7 ECAs have lower domestic content requirements than Ex-Im,
generally requiring between zero and 51 percent domestic content (see
table 2). Some ECAs with domestic content polices have more
flexibility in implementing their policies by allowing for exceptions
to their minimum domestic content requirements on a transaction-by-
transaction basis. For example, according to Japanese officials,
Japan's ECAs require a minimum of 30 percent domestic content, but the
institutions can make exceptions for projects deemed to be of
strategic importance. Ex-Im makes no exceptions to its content policy
for specific transactions, except for those involving tied aid or raw
materials.[Footnote 27] According to Canadian and Italian officials,
Canada and Italy do not require a certain level of domestic content;
rather, both consider domestic content in the context of a broad range
of factors to determine whether supporting a transaction benefits
national interest.
Table 2: Domestic Content Policies of the G-7 ECAs, Including Minimum
Domestic Content to Receive Full Medium-and Long-Term Support:
Country: United States;
Domestic content policies of the G-7 ECAs, for medium-and long-term
support: Eighty-five percent domestic content requirement to receive
full financing. If less than 85 percent, Ex-Im will finance the
domestic content portion.
Country: Canada;
Domestic content policies of the G-7 ECAs, for medium- and long-term
support: No minimum domestic content requirement. National Benefits
policy first considers the gross domestic product and employment
impacts of the transaction and then takes into account other factors,
such as increased access to global markets.
Country: France;
Domestic content policies of the G-7 ECAs, for medium- and long-term
support: Twenty percent domestic content requirement for a transaction
to be considered.[A]
Country: Germany;
Domestic content policies of the G-7 ECAs, for medium-and long-term
support: Three-tier policy: 70 percent and 51 percent minimum domestic
content for the first two tiers, respectively. For the third tier,
transactions with less than 51 percent domestic content can be
supported if there is a justification from the exporter and
Interministerial Committee approval.[B]
Country: Italy;
Domestic content policies of the G-7 ECAs, for medium- and long-term
support: No minimum domestic content requirement. The ECA supports
exports that benefit the Italian economy and has internal
considerations, such as a maximum exposure amount for a country. If
the ECA is close to reaching this amount, it will try to maximize
Italian content in the export.
Country: Japan;
Domestic content policies of the G-7 ECAs, for medium- and long-term
support: Thirty percent domestic content requirement. The ECA can make
exceptions to support projects with less than 30 percent domestic
content if the project has strategic interests.
Country: United Kingdom;
Domestic content policies of the G-7 ECAs, for medium-and long-term
support: Twenty percent domestic content requirement to receive full
support. If less than 20 percent, the ECA will support the domestic
content portion of the transaction.
Source: GAO analysis of ECA documents and interviews with officials.
Notes: ECAs from six of the seven G-7 countries, including the United
States, stated that they calculate domestic content as a percentage of
the total value of the export contract. They also stated that the
domestic content amount is self-reported, or generally self-reported,
by applicants. This table does not reflect differences in ECA policies
for supporting local costs, which can affect the amount of foreign
content supported in some transactions. Local costs are for goods and
services manufactured or originated in the buyer's country.
[A] French officials stated that going below 50 percent involves some
restrictions.
[B] The second-tier level requires between 70 to 51 percent domestic
content in certain situations, such as when the foreign content comes
from EU countries, Switzerland, Japan, or Norway and at the same time
from a third country; when it comes from German subsidiaries not
located in the buyer's country; or certain other situations. With
respect to the third tier, according to German officials, support of
such transactions is done on a limited basis.
[End of table]
EDC's Canadian Benefits policy considers the research and development
spending by the company and the potential for increased access to
global markets, among other factors, when deciding to finance a
transaction (see textbox). According to Canadian officials, the
Canadian Benefits model is designed to capture all benefits that
accrue from Canadian companies' involvement in international trade.
Text box:
In the early 2000s, Export Development Canada implemented a national
benefits policy rather than a domestic content requirement, referred
to as the Canadian Benefits model. With this model, EDC measures its
contribution to Canada's economy through the economic benefits
generated by the exports and investments it supports. EDC takes the
following steps under the Canadian Benefits model:
1. Calculate economic benefits. The economic benefits are based on the
amount of gross domestic product (GDP) in the exports it finances by
determining the amount of Canadian content in the export. The Canadian
content is provided by Statistics Canada's Input/Output Model, which
tracks the production chain of Canadian industries, and identifies and
measures inputs and outputs.
2. Calculate base grade. EDC then calculates a base grade by dividing
the level of GDP generated by the transaction by the amount of EDC
support that was requested. EDC assigns letter grades A-F according to
these support percentages.
3. Identify upgrades. Where a transaction generates a base grade of
less than B, additional benefits are considered in order to upgrade
the transaction. Each applicable secondary benefit boosts the base
grade by one letter grade. (An F rating cannot receive upgrades.)
Reasons for upgrades include the following:
* Above average research and development spending by the Canadian
company.
* The transaction allows increased access to global markets.
* The transaction has an above average employment impact.
* The Canadian exporter is a small or medium-sized business.
* The transaction supports an environmentally beneficial product.
Although transactions rarely receive low final grades, low grades do
not prevent EDC from financing the transaction, according to
EDC officials. End of text box]
In addition to the domestic content policies presented in table 2,
ECAs' policies for supporting local costs can also affect the level of
support they can provide related to goods and services that are not
sourced domestically. Local costs are for goods and services
manufactured or originated in the buyer's country, such as on-site
construction costs. Ex-Im's policy allows it to support up to 30
percent of the value of the export contract in local costs, in
addition to 15 percent foreign content.[Footnote 28] In contrast,
according to Ex-Im, the other G-7 ECAs generally include local costs
in their calculation of foreign content, and this can reduce the gap
between the level of foreign content that Ex-Im can support and that
of its foreign counterparts. Ex-Im reported that, in 2010, 21 percent
of its non-aircraft medium-and long-term transactions contained some
local cost support.
The degree to which countries rely on domestic components in producing
its exports differs. U.S. exports generally have higher domestic
content than those of other G-7 countries. OECD data show that
domestic content accounts for less than 75 percent of manufacturing
exports for five of the seven G-7 countries, but accounts for over 80
percent of manufacturing exports for the United States, as well as in
Japan.
Figure 8: Domestic Content Share of Manufacturing Exports among G-7
Countries, 2005:
[Refer to PDF for image: vertical bar graph]
Country: United States;
Percentage of manufacturing: 82.4%.
Country: Canada;
Percentage of manufacturing: 62.3%.
Country: France;
Percentage of manufacturing: 66.7%.
Country: Germany;
Percentage of manufacturing: 69.1%.
Country: Italy;
Percentage of manufacturing: 65.9%.
Country: Japan;
Percentage of manufacturing: 82.4%.
Country: United Kingdom;
Percentage of manufacturing: 71%.
Source: GAO analysis of OECD data.
Note: OECD uses input-output tables from each country to estimate the
domestic content of exports. An input-output table is a means of
presenting a detailed analysis of the process of production and the
use of goods and services (products) and the income generated in that
production. An input-output table shows the inputs that are used by
each industry, including imports, to produce its output, the output of
each industry, and the use of outputs of various industries by final
consumers. Input-output analysis can be used to study changes in the
structure of an economy.
[End of figure]
While Ex-Im Has Modified Its Method for Calculating Domestic Content,
Its Threshold for Receiving Full Financing Has Not Changed since 1987:
While Ex-Im has modified its method for calculating the amount of
domestic content in a transaction, its minimum threshold for receiving
full financing for medium-and long-term transactions has not changed
since 1987. Before 1987, Ex-Im financed only the domestic portion of
medium-and long-term transactions. If less than 100 percent of an
export's content was domestic, the foreign part would be carved out
and Ex-Im would finance 85 percent of the domestic portion.[Footnote
29] In 1987, Ex-Im adopted its current policy to allow transactions
with up to 15 percent foreign content to receive 85 percent of the
total contract value. Ex-Im's rationale for allowing up to 15 percent
foreign content was that the 15 percent down payment required by the
OECD Arrangement would cover the portion of foreign content, according
to Ex-Im officials.
In 2001, Ex-Im modified its method of calculating the domestic content
of exports in medium-and long-term transactions. Previously, Ex-Im
required exporters to report the domestic content of individual items
in a contract, line by line. In 2001, Ex-Im moved to a whole contract
value calculation where exporters report the domestic content of the
contract's entire value, rather than item by item. This allowed Ex-Im
to finance contracts that may have individual items that contain less
than 85 percent domestic content as long as the total amount in the
contract has 85 percent or more domestic content. There have not been
subsequent changes to the policy for medium-and long-term transactions.
Domestic Content of U.S. Exports Has Generally Declined and Varies
across Sectors:
Production patterns have changed in the past few decades as global
manufacturing has become more integrated. Companies increasingly rely
on parts sourced from other countries, and as a result, the domestic
content in exported goods has declined. OECD data show that from 1995
to 2005 the percentage of domestic content of manufactured U.S.
exports declined from 87.4 percent to 82.4 percent, a 5 percentage
point decline in 10 years (see figure 9).
Ex-Im does not differentiate among sectors in its domestic content
policy, although domestic content in U.S. exports varies by sector.
Among manufactured exports, medical, precision and optical instruments
showed a greater decline in domestic content, almost 6 percentage
points, than food products, beverages, and tobacco, which experienced
a 3.6 percentage point decrease. As figure 9 shows, as of 2005, the
domestic content of U.S. exports of motor vehicles, trailers, and
semitrailers was around 72 percent, and other transportation
equipment, which includes aircraft, was 83.5 percent.
Figure 9: Domestic Content of Select U.S. Exports, 1995 to 2005:
[Refer to PDF for image: vertical bar graph]
Total manufacturing:
1995: 87.4%;
2005: 82.4%.
Food products, beverages, and tobacco:
1995: 92.7%;
2005: 89.2%.
Medical, precision, and optical instruments:
1995: 90.6%;
2005: 84.8%.
Motor vehicles, trailers, and semi trailers:
1995: 81.1%;
2005: 72.1%.
Other transport equipment:
1995: 88.3;
2005: 83.5%.
Source: GAO analysis of OECD data.
Note: The data are reported in 5-year intervals because of the
availability of input-output tables for most countries. The most
recent year for which OECD did this analysis is 2005. U.S. input-
output tables use data collected every 5 years in an Economic Census
done by the U.S. Census Bureau. "Other transport equipment" covers
aircraft, a major product supported by Ex-Im financing.
[End of figure]
Given varying levels of domestic content by product and industry, Ex-
Im may be unable to provide full financing for exports in certain
industries if trends continue. Domestic content in Ex-Im transactions
fluctuated from 1997 to 2010, showing an overall downward trend. The
average domestic content for medium-and long-term transactions
containing foreign content was 91 percent in 1997 and 86 percent in
2010 (see figure 10). This value is near the 85 percent minimum
domestic content required for a transaction to receive full Ex-Im
financing.
Figure 10: Average Domestic Content for Ex-Im's Medium-and Long-term
Transactions Containing Foreign Content, 1997 through 2010:
[Refer to PDF for image: line graph]
Ex-Im threshold: 85%.
Year: 1997: 91%.
Year: 1998: 90%.
Year: 1999: 88%.
Year: 2000: 90%.
Year: 2001: 89%.
Year: 2002: 89%.
Year: 2003: 89%.
Year: 2004: 88%.
Year: 2005: 90%.
Year: 2006: 88%.
Year: 2007: 88%.
Year: 2008: 89%.
Year: 2009: 87%.
Year: 2010: 86%.
Source: GAO analysis of Ex-Im data.
[End of figure]
Concerns about Ex-Im's Content Policy Exist among Exporters and
Lenders:
Exporters and lenders have expressed concerns about Ex-Im's policy,
although obtaining clear evidence about the policy's impact is
difficult. In cases where domestic content falls below 85 percent, Ex-
Im's policy could potentially have a negative impact on U.S.
competitiveness by deterring exporters from using Ex-Im's products.
According to respondents of Ex-Im's most recent survey concerning its
competitiveness, Ex-Im's content policy is the bank's most significant
impediment to competitiveness.[Footnote 30] Exporters have urged Ex-Im
to expand its criteria for support beyond domestic content and to
consider support based on national interests. Exporters and lenders
have also suggested that Ex-Im should explore extending exceptions to
its content policy to support priority sectors, such as
environmentally beneficial projects. According to Ex-Im officials,
information on exporters that have not applied for Ex-Im financing
because of its domestic content policy or deals that have been lost as
a result of incomplete financing is not tracked.
Co-financing is a tool that some exporters can use to address
financing challenges posed by domestic content requirements, but it is
not available for all transactions. Co-financing arrangements allow an
exporter to offer a single ECA support package to a buyer interested
in procuring products from two or more countries. The G-7 ECAs have
multiple framework agreements that govern co-financing among
themselves. Ex-Im officials stated that co-financing is increasingly
used in situations where foreign content exceeds 15 percent and there
is a gap in Ex-Im's financing coverage. In 2010, Ex-Im co-financed
more than $6.5 billion in transactions, with the vast majority of
transactions involving aircraft. However, co-financing is not an
option for all U.S. transactions, because it requires meeting the
financing requirement of another country's ECA, particularly the
production of a product or service that would qualify as an export
from that country.
Other ECAs Have Modified Their Domestic Content Policies to Reflect
Changing Global Production Patterns:
Some ECAs have revised their domestic content policies to reflect
changes in global production patterns. For example, following an
evaluation 10 years ago, EDC and the Canadian government determined
that EDC's 50 percent domestic content rule had become onerous, and
that the global marketplace had changed, with more production
involving foreign content, according to Canadian officials. EDC
adopted an "integrative trade model" to reflect multiple benefits
brought to Canada from international transactions. As a result, EDC
moved to the National Benefits policy discussed above, where exporters
using little or no domestic content are eligible for support, as long
as their export is determined to benefit Canada. According to UK
officials, ECGD also substantially changed its policy in 2007,
determining that its domestic content requirement of 60 percent was an
artificial barrier and unnecessary restriction, in light of declines
in the size of the UK manufacturing base, increased globalization, and
multisourcing of goods under UK export contracts. It lowered the
requirement to 20 percent. In 2008, Germany moved from a 90 percent
domestic content requirement to its current three-tier policy that
attaches various limits to differing levels of domestic content.
Germany's federal government made these changes in response to the
repeated appeals of German exporters, who increasingly viewed the
previous system as overly restrictive in light of international
competition, according to Hermes documents and officials.
There are differing views on the ultimate impact of different domestic
content requirements, and limited analytical evidence on which to base
decisions is available. While lowering a domestic content requirement
can increase the number and type of transactions that an ECA can
support, it could lessen the incentive for some companies seeking ECA
support to source goods and services domestically. The potential
impact on U.S. employment of any changes in the policy would depend on
the balance of job gains that might accrue from supporting additional
transactions against any job losses from reduced domestic content.
As other ECAs have loosened their domestic content policies, Ex-Im's
policy remains relatively unchanged. Congress directs Ex-Im to provide
financing that is fully competitive with the financing of its
competitors.[Footnote 31] According to Ex-Im officials, Ex-Im reviews
its domestic content policy on a regular basis to identify ways to
increase flexibilities for exporters. However, Ex-Im has not conducted
a systematic review of its policy in recent years to assess to what
extent the overall impact of the policy is consistent with Ex-Im's
mission of supporting U.S. jobs.
The OECD Arrangement Has Decreased Export Credit Subsidies, But The
Increasing Importance Of Nonmembers Threatens Its Future Effectiveness:
While the scope of the OECD Arrangement has expanded to cover
additional aspects of officially supported export credit terms among
member ECAs, the increasing activities of nonmembers, particularly
China, threaten the future ability of the agreement to provide a level
playing field for exporters. Several agreements establish guidelines
for pricing and reporting on export credit support. However, these
agreements apply only to officially supported activities of
participant ECAs. Several countries, including Brazil, China, and
India, have growing ECA financing activity but are not part of the
Arrangement. Officials from several G-7 ECAs and other institutions
identify engagement with these countries to increase transparency and
promote broader discussion of export credit issues as a major
challenge that must be addressed if the Arrangement is to remain
effective.
The OECD Arrangement Has Expanded over Time to Regulate Additional
Aspects of Official ECA Support:
The scope of the OECD Arrangement has expanded over time to regulate
additional aspects of participating countries' use of officially
supported export credits, decreasing export subsidies in the process.
Since the Arrangement was formed, in 1978, there have been several
important agreements among member countries that have regulated
pricing or other aspects of export credit support. These agreements
include the following:
* Minimum interest rates. Arrangement members adopted a system of
minimum interest rates, which has reduced the interest rate subsidy
component in ECA support. These rates, called Commercial Interest
Reference Rates (CIRR), are adjusted on a monthly basis to reflect
commercial lending rates for borrowers in the domestic market of the
relevant currency.
* Minimum premium rates (risk fees). Agreements on minimum premium
rates, or risk fees, are designed to encourage convergence in pricing,
further decreasing opportunities for subsidies among ECAs. The first
agreement on risk-based premium rates, in 1997, established a set of
minimum premium rates to reflect country credit risk. Countries were
free to charge higher rates than these minimums. A new agreement,
effective as of September 2011, expanded on this earlier agreement by
including buyer credit (commercial), as well as country-based, aspects
of risk. This agreement reduces ECAs' flexibility in pricing
commercial transactions, thus further narrowing differences in ECA
financing terms.
* Tied aid. Two agreements have restricted the use of tied aid, that
is, aid conditioned on the purchase of goods and services from the
donor country. In 1987, Arrangement members agreed to raise the
minimum concessionality level for tied aid permitted under the
Arrangement to 35 percent.[Footnote 32] In 1991, a further agreement
prohibited tied and partially untied aid to richer developing
countries, as well as for projects that were considered commercially
viable.
* Sector agreements. Sector agreements have been reached for civil
aircraft, nuclear power plants, renewable energies and water projects,
and ships. Some of these agreements have different rules for minimum
interest and premium rates and maximum repayments terms than those
that apply to standard transactions through the Arrangement. The
Aircraft Sector Understanding is especially significant because it
regulates aircraft support terms for ECAs of major aircraft-exporting
countries, including the United States, Brazil, Canada, France,
Germany, and the United Kingdom. A large share of some countries' ECA
support is in the aircraft sector.
The Arrangement also has a variety of reporting requirements in
conjunction with its overall and sector agreements that provide
transparency about ECA activities to Arrangement members. ECAs must
report all of their long-term officially supported export credit
transactions to the OECD as they occur and, twice a year, report the
amount of outstanding officially supported export credits. Further,
separate reporting requirements apply with respect to minimum premium
rates as well as the aircraft sector agreement. OECD officials said
they are hoping to streamline these reporting requirements and are in
the process of approving a new data-reporting directive.[Footnote 33]
However, certain export credit transactions of member ECAs fall
outside the Arrangement and its reporting requirements, which lessens
the transparency of ECA activities. These include "market windows," or
support that an ECA provides on market terms. Canada's ECA currently
provides this type of support.[Footnote 34] The use of market windows
has historically been an issue of concern for the United States,
because of limited transparency and the potential for unfair advantage
stemming from an ECA's government connection.[Footnote 35]
A second type of transaction outside the scope of the Arrangement is
non-export credit financing activities, such as untied lending and
investment finance. A majority of G-7 ECAs offer untied lending, which
takes the form of loans extended to other countries for strategic
reasons. While these loans are not directly linked to the purchase of
exports from the lending country, the terms can take whatever form the
two countries agree upon. For instance, Japan provided an untied loan
to a commercial bank in Malaysia in order to provide long-term
financing to Japanese companies located there, as well as local
companies within their supply chain. Ex-Im officials have expressed
concern about the growing use of this financing tool because of its
potential linkage to exports and uncertainty about how its utilization
could affect Ex-Im.
Export Credits from Countries Outside the OECD Arrangement Are
Increasing:
Official export credits from emerging economies such as China, India,
and Brazil have experienced rapid growth. As nonparticipants in the
OECD Arrangement, these countries can offer terms more favorable than
terms under the Arrangement.[Footnote 36] More favorable terms to
buyers do not necessarily constitute subsidies--the terms may be
market-based and compliant with World Trade Organization requirements--
but can be more generous than those allowed by the Arrangement,
according to Ex-Im. However, since these countries are exempt from the
Arrangement's requirement to report each transaction, there is
uncertainty regarding the terms that they offer.
As total exports from emerging economies have increased, so have their
officially supported export credits. From 2006 to 2010, total exports
from China, India, and Brazil increased over 60 percent, while medium-
and long-term official export credits for China and Brazil are
estimated to have more than doubled--and for India nearly doubled--
during the same time period (see figure 11). China is now estimated to
be the largest supplier of medium-and long-term export credits.
[Footnote 37] Ex-Im estimated that China offered $45 billion in
official medium- and long-term export credits in 2010, twice as much
as Germany, the largest provider among G-7 ECAs.
Figure 11: Estimated Medium-and Long-Term Official Export Credits,
2006-2010:
[Refer to PDF for image: vertical bar graph]
Year: 2006;
Total B, C, I:
Brazil: $7.5 billion;
China: $22 billion;
India: $5.6 billion;
Total G-7: $36.3 billion.
Year: 2007;
Total B, C, I:
Brazil: $7 billion;
China: $33 billion;
India: $8.5 billion;
Total G-7: $33.4 billion.
Year: 2008;
Total B, C, I:
Brazil: $7.6 billion;
China: $52 billion;
India: $8.7 billion;
Total G-7: $41.8 billion.
Year: 2009;
Total B, C, I:
Brazil: $10.5 billion;
China: $51.1 billion;
India: $7.3 billion;
Total G-7: $62 billion.
Year: 2010;
Total B, C, I:
Brazil: $18.2 billion;
China: $45 billion;
India: $9.5 billion;
Total G-7: $65.4 billion.
Source: GAO analysis of data from Report to the U.S. Congress on
Export Credit Competition and the Export-Import Bank of the
United States, period January 2010—December 2010.
Note: Data represent the medium-and long-term officially supported
export credits issued each year by country. Ex-Im notes the
difficulties in obtaining comparable data from non-OECD ECAs because
of the lack of information. Ex-Im used a variety of methods to collect
and estimate the export credit volumes. Ex-Im notes that the figures
for China, Brazil, and India likely overstate these countries'
activities.
[End of figure]
According to China Ex-Im Bank annual reports, it provided more than
$36 billion in total export credit support in 2010, more than five
times the $4 billion provided in 2000. India's Ex-Im Bank experienced
similar growth, increasing its activities from about $500 million in
2000 to $11 billion in 2010. Over the same time period, U.S. Ex-Im's
financing increased from about $13 billion to $24.5 billion. Figure 12
compares the activities and relative growth of the Export-Import Banks
of China, India, and the United States.
Figure 12: Estimated Activity Levels for Export-Import Banks of China,
India, and the United States, 2000 and 2010:
[Refer to PDF for image: vertical bar graph]
China Ex-Im:
2000:
Loans: $3.9 billion;
2010:
Loans: $26.5 billion;
Guarantees: $10.2 billion.
India Ex-Im:
2000:
Loans: $0.5 billion;
Guarantees: $0.4 billion;
2010:
Loans: $10.5 billion;
Guarantees: $0.7 billion.
U.S. Ex-Im:
2000:
Loans: $0.9 billion;
Guarantees: $8.4 billion;
Insurance: $3.3 billion;
2010:
Loans: $4.3 billion;
Guarantees: $13.1 billion;
Insurance: $7.1 billion.
Source: GAO estimates based on annual reports from China, India, and
U.S. Export-Import Banks.
Notes: The loans from China Ex-Im Bank include seller and buyer
credits. Seller credit is broadly defined as a line of credit and can
be extended either in China's currency, the renminbi, or foreign
currencies. China Ex-Im Bank provides these credits to Chinese
enterprises for financing their construction projects implemented in
foreign countries, which may support the export of Chinese equipment,
machinery, building materials, technology, and labor services.
According to U.S. Ex-Im, the buyer credit offered by China Ex-Im Bank
is the most similar to the type of transaction-specific long-term
support made available by the G-7 ECAs.
China Ex-Im Bank reports the amount disbursed while U.S. Ex-Im and
India Ex-Im report the amount committed.
Dollar amounts shown are in nominal terms.
[End of figure]
SINOSURE, China's other ECA, also has experienced sharp growth.
SINOSURE stated in its 2010 annual report that it underwrote an
aggregate amount of $196.4 billion for that year, an increase of 68.5
percent over 2009. This follows a growth of 85.8 percent from 2008 to
2009.
Given the increase in China's officially supported export credits,
officials from some G-7 countries have expressed interest in
additional information about the terms and volume of China's
activities, but officials reported that obtaining such information is
difficult. Some information on total volume of export credits is
provided through annual reports, but in limited detail. As discussed
above, China's position outside the OECD Arrangement limits its
reporting requirements relative to G-7 ECAs. Thus, determining the
nature of its activities and the extent to which financing terms (in
contrast to other factors, such as production cost) are the key reason
for Chinese companies' securing deals is difficult. An expert on China
reported having obtained information on China's export financing
activities from recipient countries rather than from China. In
addition, officials from several G-7 countries told us that they
obtain anecdotal information on China's activities from their
exporters, who may be facing Chinese competition. One OECD official
expressed the view that China will become more competitive with the G-
7 ECAs over the next 10 years as the technology differential between
Chinese and G-7 exports decreases.
Engagement with China and Other Emerging Economies Presents Challenges
for the OECD Arrangement:
According to officials from the OECD and several G-7 ECAs, engagement
with emerging economies, especially China, on practices related to
export credit financing is increasingly important and presents
challenges for the OECD Arrangement and its participants. A senior
OECD official stated that the rise of this export financing
competition threatens the Arrangement's ability to maintain a level
playing field among exporting nations.
Various ECAs, governments, and the OECD have made efforts to engage
China on export credit issues, including encouraging participation in
various forums, but have generally reported limited success. For
example, Canadian officials reported encouraging their Chinese
counterparts to join multilateral forums. Japanese officials said they
reach out to Chinese officials on a regular basis, including at
meetings among Asian ECAs. U.S. Treasury officials noted that export
credits were mentioned at the U.S.-China Strategic and Economic
Dialogue, a high-level forum between U.S. and Chinese government
officials. They also reported that OECD and country officials have
made attempts to invite China to export credit-related meetings.
However, several ECA, government and OECD officials reported that
China is often unwilling to attend or sends lower-level
representatives to these meetings, such as a recent G-20 meeting in
Paris.
In some cases, an ECA in an emerging economy will see an incentive to
joining international agreements or institutions. In 2004, Brazil
participated in the negotiations on the Aircraft Sector Understanding
and in 2007 joined the actual agreement. One U.S. official points to
Brazil's interest in obtaining information on Canada, its primary
competitor, and a desire to help shape the rules, as strong incentives
that brought it to the negotiating table. Another institution, the
Berne Union, which is an association of export credit and investment
insurance providers, has a broad base of membership, including some of
the ECAs from China, India, and Brazil. Through membership, they have
agreed to follow certain principles, including a pledge not to
subsidize exports. This institution may provide an additional venue by
which these emerging economies can be engaged in discussions
concerning export support and related issues. However, some ECA and
other officials point to China's current lack of incentive to engage.
OECD and other officials have stressed to China one benefit of joining
the Arrangement now: the opportunity to shape the rules by which their
competitors must abide.
Conclusions:
Established with a mission to support U.S. jobs and an explicit charge
to provide export financing competitive with that of other
governments, Ex-Im is expected to play a key role in increasing U.S.
exports, be self-sustaining in terms of its budget, and fulfill a
number of policy directives beyond those of other G-7 ECAs. In terms
of its volume of export credit support, Ex-Im's performance in recent
years has been quite strong; the bank's total authorizations have
increased steadily as demand for its services has been high during a
period of global financial turmoil. Whether Ex-Im will see an
increasing tension across its mission and requirements remains to be
seen, but there is some evidence of that now, as the bank's small
business financing share for fiscal year 2011 was below its 20 percent
target for the first time in 5 years. Although small business
financing grew in 2011, it grew less than Ex-Im's overall financing.
Ex-Im's domestic content requirement for receiving full medium-and
long-term financing, which Ex-Im determines, is generally higher than
that of other ECAs and less flexible. While other ECAs have loosened
their domestic content policies in recent years, key elements of Ex-
Im's policy remain relatively unchanged. Ex-Im officials state that Ex-
Im's policy reflects its attempt to balance the interests of multiple
stakeholders and its mission to support U.S. jobs. However, to what
extent Ex-Im's current policy affects its support of U.S. jobs is not
clear-cut. It may provide an incentive for certain exporters to buy
from U.S. suppliers. On the other hand, to the degree that the
requirement limits the ability of a larger number of exporters to
obtain full Ex-Im financing, it may deter foreign buyers from sourcing
from U.S. firms. Given these factors, and trends toward increasing
global economic production, a better understanding of how Ex-Im's
policy may affect U.S. exporters and jobs is needed.
Strong increases in export financing by several emerging countries
present competitive challenges that Ex-Im alone cannot readily
address. The OECD Arrangement has made important strides toward
decreasing subsidies in export credits and leveling the playing field
for exporters. However, emerging economies with rapidly growing export
credit support levels that are outside the Arrangement are exempt from
its reporting requirements and rules and can offer terms that are more
generous than parties to the Arrangement can. Member countries have
taken some steps within the OECD and beyond it to engage countries
including Brazil, China, and India on export credit issues. However,
some acknowledge that China is not currently motivated to join any
type of agreement. There is concern that, in particular, the rise of
China's export financing threatens the Arrangement's ability to
support a level playing field among exporting nations.
Recommendations for Executive Action:
To maintain Ex-Im's competitiveness and enhance its ability to support
U.S. exports, we recommend that the Ex-Im Bank conduct a systematic
review of its domestic content policy in the context of changing
production patterns to ensure this policy effectively serves the
objective of creating U.S. jobs while also providing financing that is
competitive with that of other ECAs.
To preserve and enhance the competitiveness of U.S. exports and to
promote transparency, we recommend that the Secretary of the Treasury,
in conjunction with Ex-Im and working with international counterparts,
develop strategies to further encourage and increase engagement of
emerging economy countries in discussions and agreements on export
credit support.
Agency Comments and our Evaluation:
Ex-Im and Treasury provided comments on a draft of this report. In its
written comments, which are reproduced in appendix II, Ex-Im stated
that GAO's findings are generally consistent with Ex-Im's findings in
its 2010 Competitiveness Report and that the lack of transparency from
non-OECD ECAs is the major challenge to a level playing field
globally. Ex-Im did not directly address GAO's recommendation that it
conduct a systematic review of its domestic content policy and its
impacts but stated that it disagreed with GAO's characterization of
how Ex-Im has addressed the issue of domestic content. Treasury
provided a statement concerning its full support of engaging market
economy countries on export credit issues, but did not state whether
it agreed or disagreed with our recommendation.
With respect to its domestic content policy, Ex-Im stated that the
policy should be considered in light of Ex-Im's specific mandate to
focus on jobs. Our report emphasizes that Ex-Im's explicit mandate to
support U.S. jobs is unique among G-7 ECAs. In addition, the report
states that Ex-Im's policy is the result of an attempt to balance the
interests of multiple stakeholders with its mission to support U.S.
jobs through export financing.
Ex-Im also stated that its co-financing and local cost policies are
important in evaluating the competitiveness of its domestic content
policies. In discussing foreign content policy, our report
acknowledges the role of co-financing as a tool for some exporters,
and explicitly notes that Ex-Im provided more than $6.5 billion for co-
financing in 2010. With respect to local cost, we agree that the
treatment of local cost financing is relevant to the discussion of
foreign content, and we have added related information to the report.
Ex-Im stated it disagrees with the report's characterization of how Ex-
Im has addressed the issue of content, stating that it has regularly
reviewed the policy as part of its annual competitiveness report, and
has made changes. We do not believe that Ex-Im's competitiveness
reports constitute the systematic review of the content policy
recommended in our report, and we maintain that a more comprehensive
review, including its impact on U.S. jobs, is needed. Ex-Im's
competitiveness reports have consistently identified its content
policy as a major competitive barrier, with Ex-Im stating in its
latest report, published in June 2011, that "Ex-Im Bank's content
requirements and implementation of those requirements are
significantly more restrictive than those of its G-7 counterparts" and
that "in cases where foreign content exceeds 15 percent Ex-Im Bank's
policy and practice can have a negative impact on U.S. competitiveness
because it may deter exporters from using Ex-Im's products." Ex-Im
reported that its exporters and lenders identified foreign content as
their "most significant impediment to competitiveness." In terms of
changes made to Ex-Im's policy over time, our report states that Ex-Im
last changed its level of minimum domestic content required for
receiving full financing for medium-and long-term transactions (85
percent) in 1987 and in 2001 changed its method for calculating the
percentage of domestic content in a transaction. The report also
clearly lays out Ex-Im's content policy for short-term financing,
including specific provisions for small businesses. We have clarified
summary language regarding what aspects of the policy have not changed
since 1987. Ex-Im also provided technical comments, which we
incorporated as appropriate.
Treasury provided the following response: "Treasury fully supports and
encourages emerging market economy countries with major medium/long-
term export credit programs to join in discussions and agreements on
export credit support, and is actively engaged in that endeavor." We
describe in the report that member countries, including the United
States, have taken some steps within the OECD and beyond it to engage
emerging market economy countries on export credit issues, and that
the issue of export credits was raised at the U.S.-China Strategic and
Economic Dialogue, a high-level forum between U.S. and Chinese
government officials, including the Treasury Secretary. However, we
believe it is important that Treasury take further steps to encourage
and increase engagement of these countries on export credit issues. We
slightly modified the wording of the recommendation to reflect this.
We will send copies of this report to the appropriate congressional
committees as well as the Chairman of the Export-Import Bank and the
Secretaries of State and Treasury. If you or your staff have any
questions about this report or need additional information, please
contact me at (202) 512-4347 or yagerl@gao.gov. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on
the last page of this report. GAO staff who made major contributions
to this report are listed in appendix III.
Signed by:
Loren Yager:
Managing Director, International Affairs and Trade:
[End of section]
Appendix I: Objectives, Scope, and Methodology:
The objectives of this report were to examine (1) Ex-Im's mission,
organization, market orientation, and product offerings compared with
those of other Group of Seven (G-7) export credit agencies (ECAs), (2)
Ex-Im's policy requirements compared with those of other G-7 ECAs, (3)
Ex-Im's domestic content policy compared with those of the other G-7
ECAs, and (4) the role of the Organisation for Economic Cooperation
and Development (OECD) Arrangement in governing ECA activities.
To assess how Ex-Im's mission, organization, market orientation, and
product offerings compared with those of other G-7 ECAs, we reviewed
relevant documents, including ECA annual reports and other
publications, such as Ex-Im's annual Competitiveness Reports, OECD
reports, and legislation authorizing various ECAs. We also reviewed
ECAs' websites for additional information regarding product offerings.
We interviewed officials from each of the G-7 ECAs and government
organizations that have oversight over the ECAs. These organizations
included Ex-Im in the United States; Export Development Canada (EDC),
Department of Foreign Affairs and International Trade and Department
of Finance in Canada; Coface and the Ministry of Economy, Finance and
Industry in France; Euler Hermes, PricewaterhouseCoopers and the
Interministerial Council, represented by the Federal Ministry of
Economics and Technology, in Germany; Servizi Assicurativi del
Commercio Estero (SACE) and the Ministry of Economic Development in
Italy; Japan Bank for International Cooperation (JBIC) and Nippon
Export and Investment Insurance (NEXI) (via telephone) in Japan; and
the Export Credits Guarantee Department (ECGD) in the United Kingdom.
We also interviewed officials from the U.S. Departments of Treasury
and State, as well as the OECD and the Berne Union. In addition, we
spoke with several institutions that work in conjunction with official
ECAs: Societa Italiana per le Imprese all'Estero (SIMEST) in Italy and
KfW IPEX-Bank in Germany.
To assess how Ex-Im's policy requirements compared with those of the
other G-7 ECAs, we first examined Ex-Im's policy requirements by
reviewing Ex-Im annual reports; Ex-Im Competitiveness Reports; Ex-Im'
2010-2015 Strategic Plan; GAO reports on Ex-Im's small business
mandate, environmentally beneficial mandate, and economic impact
analysis requirement;[Footnote 38] Congressional Research Service
(CRS) reports; testimony from congressional hearings; and academic
articles. We also interviewed Ex-Im officials to talk about the
various policy requirements, and we interviewed officials from the
Small Business Administration (SBA) to discuss Ex-Im's small business
mandate. To examine the other G-7 ECAs' policy requirements and how
they compared with those of Ex-Im, we interviewed officials from the G-
7 ECAs, as well as any government organizations that play an oversight
role for these ECAs. We asked them directly whether they shared any of
Ex-Im's policy requirements, and more generally, whether they had
other policy requirements, such as requirements to focus on promoting
certain types of exports, export destinations, or exporters, and
whether this resulted from external directives or internal decisions.
We also asked about the nature of their relationships with oversight
organizations and the extent to which they received external policy
guidance from these organizations or their legislatures. In cases
where ECA officials told us that there was legislation that authorized
or otherwise governed their activities, and there were English
versions available, we reviewed this legislation. We also reviewed ECA
annual reports. We sent follow-up questions to all of the ECAs to
confirm the information they had given us during interviews regarding
their policy requirements. We also provided ECAs the opportunity to
provide technical comments on portions of the report that contain
information pertaining to the ECA.
To examine how Ex-Im's domestic content policy compares with those of
other G-7 ECAs, we first collected information on Ex-Im's policy from
its competitiveness reports and website. We reviewed testimony
transcripts from congressional hearings and literature on domestic
content of exports and global manufacturing production patterns. We
also interviewed Ex-Im officials responsible for administering the
policy, as well as officials at the Treasury Department and the
Coalition for Employment through Exports, an advocacy organization on
matters affecting U.S. government export finance. To obtain
information on other G-7 ECAs' domestic content policies, we reviewed
their annual reports. We interviewed G-7 ECA officials, who explained
their policies and provided additional documentation. We analyzed
global manufacturing production trends using OECD data on the foreign
content of the United States' and other countries' exports by sector,
from the mid-1990s to the mid-2000s. To assess the reliability of the
OECD data, we reviewed the data documentation, tested for internal
consistency of the data, and compared the trends with other sources.
We found that the data were sufficiently reliable for the purposes of
presenting global manufacturing trends, demonstrating country and
sector variances. We collected data from Ex-Im on the percentage of
foreign content in the exports it finances. Ex-Im reports this data
annually in its Competitiveness Report. We found that the data were
sufficiently reliable for the purposes of presenting the amount of
foreign versus domestic content in exports it finances.
To analyze the role of the OECD Arrangement in governing ECA
activities, we reviewed the text of the OECD Arrangement as well as a
variety of OECD and other reports on the Arrangement, Export Credit
Group, and export credit activities. We interviewed OECD officials, as
well as G-7 ECA officials, to discuss the history and evolving role of
the Arrangement as well as current challenges. We conducted a
literature search and reviewed academic literature on the Arrangement
and ECAs. To obtain information on China's export credit activities,
we met with U.S. Treasury and State Department officials in Washington
and Beijing and interviewed experts, including academic experts at
American University and the Brookings Institution. We also discussed
China's activities with G-7 ECA and other officials. To obtain data on
China's, India's, and Brazil's ECA activities, we reviewed information
from the International Monetary Fund, ECA annual reports, and Ex-Im's
2010 Competitiveness Report. We also used data published in the annual
reports from China's and India's Ex-Im Banks to compare the growth of
export financing from China and India to that of the U.S. Ex-Im Bank.
We found the data were sufficiently reliable for the purpose of
comparing levels of growth.
We conducted this performance audit from February 2011 to February
2012 in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit
to obtain sufficient, appropriate evidence to provide a reasonable
basis for our findings and conclusions based on our audit objectives.
We believe that the evidence obtained provides a reasonable basis for
our findings and conclusions based on our audit objectives.
[End of section]
Appendix II: Comments from the U.S. Export-Import Bank:
Export-Import Bank of The United States:
Fred P. Hochberg, Chairman & President:
811 Vermont Avenue, N.W.
Washington, D.C. 20571:
Phone (202) 565-3500:
Email: fred.hochberg@exim.gov:
January 19, 2012:
Mr. Loren Yager:
Managing Director, International Affairs and Trade:
U.S. Government Accountability Office:
Washington, D.C. 20548:
Re: Export-Import Bank - Actions Needed to Promote Competitiveness and
International Cooperation:
Dear Mr. Yager:
Ex-Im Bank appreciates the opportunity to offer our perspective on
GAO's findings and recommendations contained in your recently
completed report regarding Ex-Im Bank and its competitiveness compared
to other ECAs. The amount of work and level of effort GAO dedicated to
this study is impressive and fits the importance of the issue.
Overall, Ex-Im would note that the GAO findings are generally
consistent with Ex-Im's findings contained in our own Congressionally
mandated report to Congress published June 2011. (See Report to the
U.S. Congress on Export Credit Competition and the Export-Import Bank
of the United States that can be found at [hyperlink,
http://www.exim.gov/about/reports/compet/documents/2010_Competitiveness_
Report.pdf]).
Moreover, Ex-Im would also consider content a key competitiveness
element and the lack of transparency from non-OECD ECAs such as China
as the major challenge to a level playing field globally. However, Ex-
Im sees the competitiveness of content to be a more nuanced and
complex measurement than simply a comparison of maximum foreign
content regularly included in a standard transaction with 15% down and
85% ECA cover. For example, factors to which Ex-Im would give great
weight in evaluating content competitiveness would include:
* That only Ex-Im has a specific mandate to focus on jobs (for which
content is the proxy);
* That content includes an evaluation of policies regarding local
content;
* That content competitiveness must be put into the context of the
breadth of co-financing policies.
Looking at the matter of competitiveness mandates more closely, it
seems that the appropriateness of any particular level of foreign
content allowed in a standard financing must be viewed in the context
of how critical jobs are to the mission of the ECA. Ex-Im's content
policy is directly connected to its defined mission to maintain or
increase U.S. employment through the financing of U.S. exports. No
other RCA has such a mandate; in fact, some ECA's explicitly put
aspects like corporate headquarters as much more important to jobs in
a transaction. For Ex-Im, the content policy is a tool the Bank uses
to evidence support for U.S. jobs. In other words, U.S. content is a
proxy for U.S. jobs and is what the Bank relies upon to ensure that
its export financing targets the U.S. content directly associated with
goods and services exported from the U.S. For example, a competitive
aspect of the Banks current content policy structure is that the
Bank's content policy has resulted in inccntivizing sourcing from the
U.S. supplier when a company seeks to maximize Ex-Im support (often
benefiting a small business).
We also point out that Ex-Im Bank separates its content policies for
foreign content and local content while most ECAs combine all content
into one limit. Specifically, Ex-Im Bank's foreign content policy
allows 15% foreign content in a typical financing while Germany (for
example) allows 50% non-German content. However, Ex-Im may support up
to 30% of the export contract in local costs. Hence, in many larger
cases, Ex-Im Bank can extend support for to up to 45% non-U.S.
content. In contrast, the Germans support for up to 50% non-German
content includes foreign and local, thus reducing the gap between Ex-
Im Bank's content policy and its foreign counterparts to only 5%.
Moreover, Ex-Im Bank's local content policy is more flexible than our
ECA counterparts because Ex-Im does not require local costs be
explicitly included in the export contract but simply connected to the
project, while other ECAs impose an explicit limitation.
Lastly, Ex-Im Bank's "One Stop Shop" cofinancing policy provides
considerable content flexibility particularly in today's world where
several European ECAs have been downgraded with the sovereign. Ex-Im
Bank can support foreign exports under its guarantee and insurance
policy where the value of such exports was reinsured by that country's
ECA. Since 2001, Ex-Im has signed eleven (it) agreements[Footnote 1]
and has approved numerous case-specific cofinancing arrangements on
transactions with OECD ECAs with whom Ex-Im does not have a
cofinancing framework agreement.
Finally, the Bank disagrees with GAO's characterization of how Ex-Im
has addressed the issue of content. Specifically, the Bank has
regularly reviewed the content policy annually as part of the
Bank's Competitiveness Report, a process that has yielded substantive
changes over the last 20 years. Ex-Im Bank shared with your staff a
detailed chronology of its efforts, with the most recent changes
having occurred in 2008 and 2010, with a particular emphasis on small
business.
In closing, it is important to note that Ex-Im's book of business is
comprised of aircraft transactions representing roughly 33% for which
content poses no competitive issues. Project Finance represents
another 33% of which co-financing is often used to cover the foreign
content. Most of the remaining 33% is represented by short term, most
of which is small business, and represents the area with the most
liberal and flexible of Ex-Im's content policies. Accordingly, the
number and frequency of cases challenged by Ex-Im's content policies
that could be at a competitive disadvantage is now fairly small.
Sincerely,
Signed by:
Fred P. Hochberg:
President and Chairman:
Footnote:
[1] Ashr'a (Israel), Atradius (Netherlands), Coface(France), ECGD
(UK), EDC (Canada), EFIC (Australia), EKF (Denmark), Hermes (Germany),
KEXIM (Korea), NEXI (Japan), and SACE (Italy).
[End of section]
Appendix III: GAO Contact and Staff Acknowledgments:
Contact:
Loren Yager, (202) 512-4347 or YagerL@gao.gov.
Staff Acknowledgments:
In addition to the person named above, José Alfredo Gómez (Acting
Director), Celia Thomas (Assistant Director), Jennifer Young, Vaughn
Baltzly, Ming Chen, Laura Erion, and Arthur Lord made key
contributions to this report. Also contributing to this report were
Lynn Cothern, David Dornisch, and Ernie Jackson.
[End of section]
Footnotes:
[1] The OECD is an organization of 34 industrialized countries,
operating by consensus, that fosters dialogue among members to
discuss, develop, and refine economic and social policies and provides
an arena for establishing multilateral agreements.
[2] They can take the form of "supplier credits," extended by the
exporter, or "buyer credits," where the exporter's bank or financial
institution lends to the buyer or to the buyer's bank.
[3] These are Ex-Im's definitions. Ex-Im and OECD officials noted that
there are not consistent definitions for "short-term," "medium-term,"
and "long-term."
[4] Ex-Im's budget includes its program subsidy and its administrative
expenses. Program subsidy refers to budgetary resources that must be
allocated annually to reserve against any estimated costs to the
government of Ex-Im's activities (such as due to defaults) not covered
by fees and other payments, on a net present value basis. The fees
charged by Ex-Im have covered its annual subsidy and administrative
costs in recent years. Congress retains oversight of Ex-Im's budget by
setting annual limits on Ex-Im's use of its funds for program subsidy
and administrative expenses.
[5] Overseas investment loans (loans to help domestic firms invest
abroad) and untied loans (loans extended to foreign governments or
companies for the purpose of providing credit for strategic reasons)
are offered by JBIC. Overseas untied loan insurance, which protects
Japanese companies and banks from losses associated with providing
untied loans, is provided by NEXI.
[6] Specifically, the remaining G-7 countries had the following
shares: United States: 0.6 percent, Canada: 0.3 percent, France: 1.1
percent, Germany: 0.6 percent, Japan: 0.2 percent.
[7] We found that the data presented in Ex-Im's Report to the U.S.
Congress on Export Credit Competition and the Export-Import Bank of
the United States, period January 2010 through December 2010 (Ex-Im
2010 Competitiveness Report) provide the best available estimate of
the G-7 ECAs' medium-and long-term officially supported export
credits. The amounts are estimated because some ECAs do not
specifically report this information. Rather, they report on their
total business, only a subset of which can be considered "officially
supported" export credits. This makes it very difficult to obtain the
information shown in figure 3 from ECA annual reports.
[8] The European Union is an economic and political partnership among
27 European countries. Austria, Belgium, Bulgaria, Cyprus, the Czech
Republic, Denmark, Estonia, Finland, France, Germany, Greece, Hungary,
Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, the Netherlands,
Poland, Portugal, Romania, Slovakia, Slovenia, Spain, Sweden, and the
United Kingdom are members.
[9] The Arrangement also governs the use of "tied aid"--aid
conditioned on the purchase of goods and services from the donor
country.
[10] The latest version of the Arrangement dates from September 2011.
An important change was the introduction of new buyer risk
(commercial) premium rates, which came into effect on September 1,
2011.
[11] Canada experienced a large increase in 2009, which is largely
related to restructuring of the automotive sectors in Canada and the
United States.
[12] As shown in figure 4, some of the European ECAs have interest
make-up programs, which are designed to facilitate fixed-rate lending
and provide an alternative to direct loans. However, according to Ex-
Im and Treasury officials, because of the reliance of such programs on
commercial banks as intermediaries and a lack of liquidity during the
financial crisis, Ex-Im's direct loan product was more competitive.
[13] Ex-Im interprets the term "make available" as a target that the
bank is expected to meet.
[14] In fiscal years 2002-2005, Ex-Im did not reach the goal, with its
small business financing share ranging from 16.9 percent to 19.7
percent.
[15] In terms of total number of transactions, transactions involving
small business directly account for the bulk of Ex-Im financing
because they are on average much smaller in value than transactions
that directly involve larger businesses. In 2010, about 88 percent of
the total number of Ex-Im's transactions directly benefited small
business and about 25 percent were made available to non-small
business. (The percentages do not sum to 100 because some individual
transactions could be used to directly benefit multiple parties,
including both small and non-small businesses.)
[16] Ex-Im officials said they requested funding in fiscal year 2011
for expanding small business outreach efforts, but that funding was
not included in their final budget.
[17] Ex-Im's financing of exports it identified as environmentally
beneficial was 1.3 percent of its total financing from fiscal year
2003 through the first half of fiscal year 2010. Its financing of the
more narrowly defined category of renewable energy and energy-
efficient technologies would be much smaller than 1.3 percent of its
total financing. We found that Ex-Im could improve its planning and
use of resources in this area, although the difficulty of meeting
these targets with existing resources remained to be seen. GAO, Export-
Import Bank: Reaching New Targets for Environmentally Beneficial
Exports Presents Major Challenges for Bank, [hyperlink,
http://www.gao.gov/products/GAO-10-682] (Washington, D.C.: July 14,
2010).
[18] Ex-Im has additional requirements. They include, for example,
annual reporting requirements on its small business activities and the
requirement to develop a program for providing support with respect to
the export of high technology items to countries making the transition
to market-based economies.
[19] To be eligible for Ex-Im support, Ex-Im requires that certain
transactions be shipped exclusively on U.S.-flagged vessels if the
cargo is oceanborne. These transactions include (1) direct loans,
regardless of the amount, and (2) guarantee transactions with either
(a) a financed amount greater than $20 million or (b) a repayment
period greater than 7 years.
[20] In 2002, Ex-Im's energy financing, specifically its financing for
fossil fuel projects, was the subject of a lawsuit brought against the
bank and the Overseas Private Investment Corporation by environmental
nongovernmental organizations and four U.S. cities. Friends of the
Earth, Inc., et al. v. Spinelli, et al. (Civ. No. 02-4106, N.D. Cal.)
The lawsuit asserted that Ex-Im and the Overseas Private Investment
Corporation (OPIC) provided assistance for fossil fuel projects that
caused greenhouse gas emissions without complying with provisions of
the National Environmental Policy Act requiring assessments of their
projects' impacts on the U.S. environment resulting from their
emissions. The lawsuit was settled in 2009 with Ex-Im agreeing to
develop and implement a carbon policy for Ex-Im's financing; provide
the Board of Directors with additional information about carbon
dioxide emissions associated with potential fossil fuel transactions;
and take a leadership role in consideration of climate change issues,
promoting emissions mitigation measures within the Organisation for
Economic Cooperation and Development and among export credit agencies.
[21] The enhanced due diligence process is an early review by Ex-Im's
Board of high-carbon-intensity projects, such as coal-fired power
plants, which includes a requirement for verifiable offsets to reduce
the carbon dioxide intensity of projects in the highest category.
[22] For information on Ex-Im's economic impact assessment process,
see GAO, Export-Import Bank: Improvements Needed in Assessment of
Economic Impact, [hyperlink, http://www.gao.gov/products/GAO-07-1071]
(Washington, D.C.: Sept. 12, 2007).
[23] Specifically, congressional notification is required if the
transaction is for the export of technology, fuel, equipment,
materials, or goods or services to be used in the construction,
alteration, operation, or maintenance of nuclear power, enrichment,
reprocessing, research, or heavy water production facilities.
[24] Financing 85 percent of the total value of a transaction is
considered full financing because of the provision under the OECD
Arrangement that ECAs can finance only 85 percent of a transaction's
value.
[25] Thus, the domestic content percentage of a transaction is
calculated as a fraction of the total value of the transaction,
including direct costs, indirect costs, and profit.
[26] For small businesses' short-term transactions, Ex-Im requires
that the aggregate U.S. content of all products in an export
transaction must be more than 50 percent. The amount of foreign
content is calculated from the exporter's total direct and indirect
costs, excluding profit. For non-small businesses, Ex-Im requires that
each product in an export transaction have at least 50 percent U.S.
content. In addition, the amount of foreign content is calculated from
the exporter's direct cost only.
[27] Ex-Im makes exceptions to its domestic content requirement for
tied aid, which has been used by Ex-Im four times in the last 10
years. According to Ex-Im officials, in addition to tied aid, Ex-Im
allows raw materials that originated outside the United States to be
considered 100 percent U.S. content when the raw material is
significantly transformed (i.e., loses its identity) and constitutes a
minimal (small) portion of the value of the end product.
[28] In 2007, the OECD Arrangement participants agreed to raise the
proportion of local costs that may be officially supported in an
export contract from 15 percent to 30 percent of the export contract
value on a trial basis through the end of 2010. In 2008, Ex-Im
increased its maximum local cost support to 30 percent. In January
2011, the local cost provision was made permanent in the Arrangement
text.
[29] Thus, for a transaction with an export value of $100, of which
$10 was foreign content, Ex-Im would have financed $76.50 before 1987
($90 x 0.85) and would finance $85 under its current policy.
[30] Congress requires Ex-Im to conduct an annual survey of exporters
and lenders who have used Ex-Im's medium-and long-term programs in the
prior calendar year to determine their experience using the bank's
programs and to compare these programs with those of other ECAs. Ex-
Im's most recent report, published in June 2011, covers the period
January 1, 2010, through December 31, 2010.
[31] According to Ex-Im's charter, Congress directs Ex-Im to provide
guarantees, insurance, and extensions of credit at rates and on terms
and other conditions that are fully competitive with the government-
supported rates and terms and other conditions available for the
financing of exports of goods and services from the principal
countries whose exporters compete with U.S. exporters.
[32] Concessionality refers to the percentage of financing that is a
grant or grant equivalent.
[33] In the past, the OECD released an annual report containing
aggregations of the data that ECAs reported on their export credit
transactions. However, according to OECD officials, the last report
issued was for 2005, and in recent years, their data collection
mechanism has not allowed for sufficiently reliable reporting. The
officials said they plan to begin releasing these data again in early
2012. They hoped this would coincide with the implementation of the
new data reporting directive.
[34] Italy's ECA, SACE, operates a market window for some non-export
credit activities. SACE officials emphasized that all of its export
credit transactions fall under Arrangement terms. Germany's KfW IPEX-
Bank, owned by KfW Bankengruppe (KfW), also operates a market window.
KfW was criticized as having an unfair advantage because it had access
to cheaper funding for export lending and project finance activities
because of its state backing. In 2002, as part of a settlement with
the European Commission, Germany agreed to separate KfW's commercial
business from the rest of its activities, and in 2004, it began
conducting much of its export credit and project finance activities
through KfW IPEX-Bank. In 2008, KfW-IPEX-Bank became an independent
legal entity.
[35] Although the financing is market-based, the ECAs delivering it
have a government connection and can enjoy benefits associated with
that status, such as tax exemptions. In addition, one concern has been
that ECAs with market windows might use profits from the market
transactions to subsidize their transactions under the Arrangement.
[36] Arrangement members are permitted, consistent with international
obligations and the purpose of the Arrangement, to match financial
terms and conditions offered by nonmembers.
[37] China has two official ECAs--China Ex-Im Bank and Sinosure. China
Ex-Im Bank offers loans and loan guarantees; it also offers
concessional loans that are comparable to what the OECD refers to as
"official development assistance." Sinosure is an export credit
insurer and offers programs covering short-, medium-and long-term
export credit insurance as well as foreign investment insurance. China
Development Bank, a Chinese policy bank, does not consider itself to
be an official ECA, but has offered export credit financing. In some
projects it finances, it stipulates that a certain amount of materials
and equipment have to be sourced from China.
[38] See GAO, Export-Import Bank: Performance Standards for Small
Business Assistance Are in Place but Ex-Im Is in the Early Stages of
Measuring Their Effectiveness, [hyperlink,
http://www.gao.gov/products/GAO-08-915] (Washington, D.C.: July 2008);
Export-Import Bank: Reaching New Targets for Environmentally
Beneficial Exports Presents Major Challenges for Bank, GAO-10-682
(Washington, D.C.: July 2010); and Export-Import Bank: Improvements
Needed in Assessment of Economic Impact, [hyperlink,
http://www.gao.gov/products/GAO-07-1071] (Washington, D.C.: September
2007).
[End of section]
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Katherine Siggerud, Managing Director, siggerudk@gao.gov, (202) 512-4400
U.S. Government Accountability Office, 441 G Street NW, Room 7125
Washington, DC 20548.
Public Affairs:
Chuck Young, Managing Director, youngc1@gao.gov, (202) 512-4800
U.S. Government Accountability Office, 441 G Street NW, Room 7149
Washington, DC 20548.